EPA/IMSD/91-020
                               November 1991
Model Regional Records
 Management Operating
   Procedures Manual
           (Draft)
           NRMP
  National Records Management Program
Information Management and Services Division
   U.S. Environmental Protection Agency
       RoomM2003 PM-211D
         401 M Street, SW
       Washington, DC 20460

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               TABLE  OF  CONTENTS
       L  INTRODUCTION 	 1
          1.  Background	 3
          2.  Purpose	 5
          3.  Approach	 5
          4.  Organization	 6

       IL  EPA'S RECORDS MANAGEMENT PROGRAM	 7
          1.  EPA's Records Management Program Requirements and
                Objectives	.	 9
          2.  Owners, Users and Custodians of Recorde'd Information	 12
          3.  Records Life Cycle	 13
          4.  Records Management Roles and Responsibilities	 17
          5.  Organization and Staffing	 20
          6.  Records Center Concept	 23
          7.  Functions and Services	 24
          8.  Career Growth and Development	 29
          9.  Planning	 31
         10.  Budgeting	 32
         11.  Records Management Needs	 33
         12.  Use of Contractors	 38

      m.  RECORDS MANAGEMENT PROGRAM COMPONENTS	 43
          1.  Records Inventory	 45
          2.  Records Classification/File Plans	 57
          3.  Document Control	 83
          4.  Records Disposition	 97
          5.  Vital Records	 121
          6.  Information Security	 145
          7.  Accommodating Public Access Requirements	 153
          8.  Electronic Records Management Technology	 167
          9.  Regional Staff Communication	 185

     APPENDIX A:  Inventory of  Records Management Studies
                   for EPA

     APPENDIX B:  Reference Documents Concerning Staffing

     APPENDIX C  Applicable Guidance Report
Model Regional Records Management Manual          (November 1991 draft)

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     I.    INTRODUCTION
          1.   Background




          2.   Purpose




          3.   Approach




          4.   Organization
Model Regional Records Management Manual         (November 1991 draft)

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       I.    INTRODUCTION
           The overall goal of this document is to provide a blueprint for
      regional managers who want to position their organizations for better
      performance in the  future. It responds  to  requests from Assistant
      Regional Administrators, regional information resources management
      (IRM)  chiefs,  and  other regional managers  who recognize  the
      contributions  an effective records  management program makes to
      meeting EPA's environmental mission. The  recommendations in  this
      model will guide mangers in  developing a program which promotes
      consistent standards for quality service across all records management
      activities in  the regional office.  This document is intended to facilitate
      many regional improvements already underway. These improvements
      share a common objective of improving  access  by all  regional
      managers and staff  to information from all regional program and
      management offices.  It is also intended to foster the management and
      organizational  capabilities that are the necessary prerequesites  for
      improving  productivity by  introducing the  use of information
      technology.

      1. Background	

           The Office of  Information Resources  Management (OIRM) in
      EPA's Office of Administration and Resources Management (OARM) is
      responsible  for the  management of  EPA's  records as an  essential
      component  of the Agency's comprehensive  IRM  program.  Through
      the  national  records management  program  (NRMP),  OIRM  is
      providing the leadership and  technical  expertise  to  improve  the
      management of recorded information throughout the  Agency.

           Over  the past three years,  OIRM has been examining  the
      organization and functions of EPA's records management program.  A
      major theme  is how to promote  consistently high standards  for
      managing records across EPA's  highly decentralized organization.
      OIRM,  the Office of Solid Waste and Emergency Response (OSWER),
      and EPA regional offices have commissioned  studies  that examine  the
      Agency's strategic  needs  for  electronic recordkeeping,  in both
      headquarters and regional  records management  programs  and,  in
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Introduction .
      particular, regional Superfund records management initiatives.  (See
      Appendix A Inventory of Records Management Studies for EPA.)  In
      addition records management jraining was developed for regional
      managers and records staff. This Model Regional Records Management
      Operating Procedures Guidance is the next step in the NRMPs  plans to
      improve records management program guidance available to the
      regions.

           In January of 1989, the Director, OIRM, issued a  memorandum
      titled "Revised Regional Information Resources Management Model
      to Include Records Management Support" that  described the records
      management function to be developed in each EPA regional office. (See
      Appendix B for  a  copy   of  this  memorandum.)  The  model
      recommended  that  two  major  records management  functions  be
      included under the  responsibilities  of  the  Assistant Regional
      Administrator and the regional IRM manager. These key functions are:

           •     Management of the full records life cycle

           •     Operation of records center(s).

      Although  the memorandum  established  the  principle of  records
      management as  a component of a comprehensive IRM—program and
      suggested an organizational  framework,  it did not  analyze how
      managers should implement  this program.

           OSWER has  led improvements in how regions manage key
      Superfund documents, such  as the Administrative Record. • OSWER
      has also assessed the program's  comprehensive records management
      needs in the Superfund Document  Management Study. The study
      identified  several issues across all regions, including inconsistent
      standards, a lack of definitive guidance, tremendous costs and inherent
      risks associated with current  Superfund document  management
      practices. Many of the problems stem, at least in part,  from a lack of
      guidance that should be provided  to all regional programs by the
      NRMP  in OIRM. This document provides a model procedural and
      guidance framework within which Superfund and regional managers,
      especially the  Assistant  Regional  Administrator, can plan and
      implement improvements.
               (November 1991 draft)     .     Model Regional Records Management Manual

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                                                          Introduction
2. Purpose
      The  overall  purpose  this  document is to  guide  regional
managers as they  establish  records  management  programs  which
provide ongoing operational support to all regional staff. The guidance
is focused on addressing issues of both efficiency and performance.

      Efficiency issues - All regional offices have limited  space in
which to operate and house  their  records.   Therefore, continuing to
store large volumes of paper records in individual offices and to create
and store duplicate copies of many records is not viewed as an efficient
use of space. Additionally, requiring each individual office to manage
its own records service contracts is not  seen as the most efficient use of
the region's  resources.

      Performance issues - Completion of most media program and
administrative  office  activities  requires access  to records.  Records
which are stored in individual offices or other dispersed locations are
not easily accessible to staff who need  to refer to them.  The Agency's
movement toward cross-media  information integration  to support its
environmental decisionmaking has further magnified the importance
of access to records.  EPA is also experiencing rapid growth  in the
number of requests from Congress, public  interest groups and the
general public for information from Agency documents and records.

3. Approach	

      The approach to producing this document involved compiling
and reviewing current  EPA  and other federal government policy,
guidance documents, and  records management studies. Additionally,
discussions  were  held  with  EPA headquarters and regional  staff
responsible for records management to  identify topics and issues which
should be included. This document is designed as a reference tool that
complements other EPA and regional guidance.  Regional records
managers may  use this  document to  complement their collection of
existing policies and guidance on records management or of particular
program directives and procedures.  The Superfund program, for
example,  has  produced  policy  and  guidance  governing  the
management of site files and the Administrative Record.
Model Regional Records Management Manual     (November 1991 draft)

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Introduction
      4.  Organization
           This document is organized into three main sections with the
      following topics discussed in each section:

            •     Introduction  - describes  the purpose, background and
                 approach to developing this guidance.

            •     EPA's Records Management Program - reviews federal
                 and  EPA requirements governing  the management of
                 recorded information, reviews the life cycle of records,
                 defines the roles and  responsibilities of the records
                 manager and  presents a model for a Regional Records
                 Center.

            •     Records Management Program Components - describes
                 the basic elements of a regional  records management
                 program in terms of objectives, legal and administrative
                 requirements,  and  approaches  for  establishing and
                 managing each component.

      Three appendices provide easy access to more detailed documents
      referenced in the guidance.
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     II.   EPA'S  RECORDS
           MANAGEMENT  PROGRAM
      1.   EPA's Records Management Program Requirements
          and Objectives
      2.   Owners, Users and Custodians of Recorded Information
      3.   Records Life Cycle
      4.   Records Management Roles and Responsibilities
      5.   Organization and Staffing
      6.   Records Center Concept
      7.   Functions and Services
      8.   Career Growth and Development
      9.   Planning
     10.   Budgeting
     11.   Records Management Needs
     12.   Use of Contractors
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      II.  EPA's RECORDS  MANAGEMENT
           PROGRAM
           This section discusses the basic requirements, objectives, and
     composition of EPA's records management program. It also introduces
     the concept of a Regional Records Center. The  following topics are
     included:

           •    Legal and administrative requirements for EPA's records
                management program

           •    Objectives of EPA's records management program

           •    Owners, users, and custodians of recorded information

           •    Records life cycle as it relates to the records management
                program

           •    Records management roles and responsibilities

           •    Model regional records management  program.

     Each of these topics will be discussed in detail in the following sections.

     1. EPA's Records Management Program Requirements and
        Objectives	

           The statutory basis for EPA's records management program is
     contained in two laws: the Federal Records Act of  1950, as amended (44
     U.S.C.) and the Paperwork Reduction Act of 1980 (44 U.S.C.).  The
     Federal Records Act provides that the head of each federal agency will
     establish and maintain  a continuing program for the  economical and
     efficient management of the records of the agency and establishes the
     oversight  responsibilities of the National Archives and Records
     Administration  (NARA) and the General Services  Administration
     (GSA). The Paperwork Reduction Act makes records management a
     component of the broader federal information resources management
     program.  These Acts provide the legal foundation for EPA's records
     management program and, more specifically, require  federal agencies
     to:


Model Regional Records Management Manual          (November 1991 draft)

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Records Management Program
            •     Create and preserve federal records containing adequate
                  and proper documentation of the organization, functions,
                  policies, decisions, procedures, and essential transactions
                  of the agency and the records necessary to protect the legal
                  and financial rights of the government and of persons
                  directly affected by the agency's activities (44 U.S.C. 3101)

            •     Cooperate with NARA and GSA in applying standards,
                  procedures, and techniques to improve the management
                  of records; promote the maintenance of records of
                  continuing value; and facilitate segregation and disposal
                  of temporary  records (44 U.S.C. 3102)

            •     Establish effective management controls over the
                  creation, maintenance, and use of federal records (44
                  U.S.C.  3102)

            •     Submit to NARA lists and schedules of federal records
                  proposed for  disposal (44 U.S.C. 3303)

            •     Comply with the provisions of all schedules approved
                  and issued by NARA (44 U.S.C. 3303a)
                                                             -'r' '  *•• '
            •     Destroy federal records only with the approval of NARA
                  and in accordance with established procedures (44 U.S.C.
                  3314)

            •     Establish safeguards against the unauthorized removal or
                  destruction of federal records and notify NARA if
                  removal or destruction occurs or threatens to  occur (44
                  U.S.C.  3105 and 3106)

            •     Comply with NARA directions to transfer records that are
                  over 30 years old, except when the agency head certifies in
                  writing that the records are necessary to conduct the
                  regular, current business oHhe agency (44 U.S.C. 2107)

            •     Comply with all records management regulations issued
                  by NARA and GSA (44 U.S.C. 3102 and 3303).

            Building upon  the requirements set forth in the Federal Records
      Act and the Paperwork Reduction, EPA has established a body of policy
      which contains more specific records management requirements  for
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                                                Records  Management Program.
      the Agency.   These requirements  are  contained  in  the  following
      documents:

            •    1977 Delegation of Authority to Field - redelegates
                 authority for records management programs from the
                 Office of Administration and Resources Management
                 (OARM) to the regional offices

            •    1985 EPA Records Management Manual - prescribes
                 objectives, responsibilities, and procedures for the conduct
                 of EPA's records management program

            •    1987 Information Resources Management (IRM) Policy
                 Manual - establishes a policy framework for EPA's IRM
                 program, including records management

            •    1989 Memorandum on Revised Regional Information
                 Resources Management Model - revises the Regional IRM
                 Model to include records management support;
                 recommends the placement of the records management
                 function under the authority  and direction of the regional
                 IRM branch; and recommends the establishment of a
                 Regional Records Center(s).
                                                *'.
      These  documents  establish  the  fundamental  administrative
      requirements that EPA's records management programs must meet.

            In  addition to  these  requirements, the Agency's  records
      management program activities must also meet a set of unique  needs
      dictated by EPA's mission and functions.  These needs are as follows:

            •    Environmental litigation and cost recovering  actions
                 undertaken on the behalf of the Agency require  that
                 documents can be submitted as evidence in court.
                 Therefore, EPA must ensure that its documents  are
                 accessible and that the integrity (i.e., chain of custody) of
                 the documents is maintained.

            •    EPA's media program documents have a long active life
                 and, therefore, must often be maintained on-site or be
                 readily accessible for long periods of time.

            •    The public has a right to view many of EPA's records as
                 determined through the  Freedom of Information Act
                 (FOIA), the Comprehensive Environmental Response,

                         1** -T+-
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Records  Management Program
                 Compensation, and Liability Act (CERCLA), and other
                 legislation. This requires EPA to make its records
                 available to the public.

            •     Tremendous growth in document volume has occurred
                 over the evolution of the Agency, and growth is expected
                 to continue. This requires EPA to manage a large volume
                 of records.

      EPA has established a two-fold goal for records management:

            •     Preserve the Agency's official records (as explained above)

            •     Promote access to needed information.

      Both  goals  are required  to meet  federal records management
      requirements as well as EPA's unique needs for recorded information.

            EPA's records management  goal  of  facilitating access to the
      Agency's information  is necessary to ensure that EPA staff have the
      information they need to perform their jobs and that members of the
      public are able to obtain the information in which they are interested.
      The implementation of records centers  is critical to achieving this  goal.
      However, to  further facilitate access, EPA should consider moving
      toward an integrated service center concept which would combine the
      responsibilities of the records center with those of the regional library
      and the regional information center.  This would provide one central
      point, under the auspices of the Information  Resources Management
      Branch, where indices to all  the region's  documents and  other
      information would  be maintained.  Therefore, EPA staff or members of
      the public could either obtain'the  information in which  they  were
      interested from the service center or be directed to the location of the
      information.   Additionally, the organization of these  information
      services under one umbrella would  poise the  region  to  take full
      advantage of advanced information  technologies  and other initiatives
      to improve the management of information in the region.

      2. Owners, Users and Custodians of Recorded Information

            EPA's records management  program defines the cooperative
      roles  of information owners,  users  and  custodians in  managing
      records. These three roles are defined as follows:
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                                                 Records  Management Program
            •     The owner is the creator and generally the primary user of
                  the record. Ownership involves authority and
                  responsibility for the information, either in a
                  programmatic or general management sense. For
                  example, the hazardous waste division is the owner of
                  Superfund's Administrative Record.  The owner
                  determines the value and sensitivity of the information.
                  These decisions are key criteria used by records managers
                  in determining, in  consultation with the owner, whether
                  the information is an official record or a non-record (such
                  as personal papers  or reference material.) The owner's
                  decisions should reflect not only the immediate need for
                  the record but should also anticipate the needs of other
                  users.

            •     Users include all individuals and organizations who are
                  authorized by the Agency or the owners to access the
                  recorded information.  Users include EPA staff and their
                  agents (such as authorized contractors and grantees), other
                  governmental organizations both domestic and
                  international, as well as the general public.

            •     Custodians possess the paper files or information
                  technology equipment housing the recorded information.
                  For example, the Air Docket is the custodian of records
                  documenting the development of regulations governing
                  EPA's air programs under the Clear Air Act as amended
                  and the headquarters library is the custodian of the
                  Hazardous Waste Collection.  Custodians have the
                  knowledge, the skill, as well as the accountability for
                  processing, storing, circulating and updating the records.

            These  roles are not always discrete;  the owner can  be the
      principal user and custodian of the  information.  For example, EPA
      executives are the owner, user, and  custodian of the official records
      (such as correspondence and  appointment  logs)  documenting the
      decisions  and  accomplishments under their  tenure in office.  The
      following discussion  of the life cycle of records helps illustrate the
      various roles of owners, users and custodians.

      3. Records Life Cycle	

            Effective management  of records  begins when information is
      recorded by the owner  as  a  document, image or form. Records
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Records Management Program
      management is more than the disposal of inactive records no longer
      used to accomplish the work of an organization.   The life cycle of the
      Agency's records varies in  detail according to  the type  of record.
      However, the records life cycle is  generally divided into the following
      stages (the life cycle is illustrated graphically on the next page):

            •     Creation - The objective of the records management
                  program in  this phase is to determine how documents
                  will support the immediate and longer-term needs of  the
                  Agency.  These decisions shape the management structure
                  for classifying and filing records, whether in paper,
                  electronic, or other format, at the time of creation. The
                  owner is accountable  for determining the value of the
                  record and establishing appropriate procedures to ensure
                  its integrity and availability. The custodian provides
                  records management  expertise which should help
                  establish effective stewardship of the  Agency's
                  information resources.

            •     Maintenance - The objective in this phase is  to ensure
                  that all records are available when needed. Maintenance
                  includes ongoing filing and retrieval  of records. Owners,
                  users, and custodians share accountability for the
                  successful maintenance of records.  Obtaining this
                  objective involves supporting  the utilization  of records
                  within the Agency by circulating the records among staff
                  who need to use them and performing tracking, filing,
                  indexing, and other organizational functions. Depending
                  on the length of the active life of the  records,
                  management of this phase and the next may require the
                  establishment of ongoing records support services by
                  dedicated records management staff.

            •     House Cleaning - During this  phase, the accumulated
                  materials of an office  are organized for more effective  use
                  and storage. Information of no continuing value is
                  removed from the office. The remaining information
                  with enduring value is organized according to established
                  plans which include an  office's records inventory, file
                  plans, and approved disposition schedules. This phase
                  includes monitoring the usage of files and recycling those
                  records which are no  longer needed.  It is the shared
                  responsibility of owners and custodians to plan and
                  implement regular house cleaning.  This phase is most
14              (November  1991 draft)           Model Regional Records Management Manual

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                                                      Records Management Program
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Model Regional Records Management Manual
(November  1991 draft)
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Records Management  Program
                  effective when it is incorporated into the ongoing office
                  routines and practices and accomplished according to
                  updated plans.  Most EPA offices experience frequent
                  changes in functions and responsibilities, all of which
                  result in records.  The plans which help organize their
                  records, therefore, need to be kept current with their
                  information requirements.

                  Records Disposition - The records management objective
                  in this phase is to dispose of official records according to
                  the instructions in the approved disposition schedules.
                  There are  three basic choices:

                        Immediate destruction
                        Transfer to the Federal Record Center (FRC) and
                        destroy later
                        Transfer to FRC and later to the National Archives
                        for  permanent retention.

                  Records disposition involves monitoring all official
                  records and identifying, according to disposition
                  schedules, which option is correct.  The custodian of the
                  records is  responsible for records disposition with the
                  approval of the owner.

                  Recall from FRC - The objective in this phase is to assist
                  the program or management office with obtaining records
                  that were  previously retired to the FRC. Users initiate the
                  request, which is approved by the owner and carried out
                  by the custodian.  This phase requires the custodian to
                  request the recall; to monitor and track all requests from
                  the FRC through logging the requests, completing the
                  appropriate forms, and monitoring the status of the
                  request; and to ensure the return of the records to the
                  FRC.  The user is accountable for returning the
                  information in the same condition as received and within
                  timeframes established upon receipt of the information
                  from  the custodian.

                  Final  Disposition - The objective of this last phase is to
                  ensure that records with permanent value are transferred
                  to the National Archives and that information with no
                  continuing value is destroyed.
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                                                 Records Management Program
                        Archiving - Some records with permanent value
                        are transferred to the National Archives as a record
                        of official governmental transactions.  The
                        custodian assists the owner in completing the
                        standard forms that accompany records being
                        transferred and helps pack the records according to
                        FRC specifications.

                        Destruction - The objective of the records
                        destruction phase is to ensure that records the FRC
                        is storing with an intent to destroy at a specified
                        date, according to the disposition schedule, are
                        indeed no longer of value to their owner. Explicit
                        approval for destruction is required from the owner
                        with the assistance of the custodian.

            This description of records life  cycle is consistent with federal
      policy  which  holds  that records  management,  like  other  IRM
      programs, must support the overall mission of the Agency. The Office
      of Management and Budget (OMB) Circular A-130, issued December 24,
      1985  to guide  federal  agencies in  implementing  the Paperwork
      Reduction  Act, mandates  the  following  standard  for effective
      management of recorded information:
         "...create or  collect only that information necessary for  the proper
         performance  of agency functions and  that has  practical  utility,
         and  only  after  planning  for  its  processing,  transmission,
         dissemination,  use, storage and disposition."
      4. Records Management Roles and Responsibilities
            EPA's records management program is organized and managed
      in accordance with the Agency's decentralized organizational approach
      which maximizes regional operational  effectiveness. Headquarters,
      regional offices, and laboratory records managers must work together
      to obtain the records management goal of ensuring that the Agency's
      records are  complete,  accurate, and   accessible,  thus  facilitating
      environmental  decisionmaking and the ability of the public to access
      EPA's information. The  general responsibilities of each organization
      can be summarized as follows:
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Records Management  Program
            •     The headquarters offices maintain the Agency's official
                  records for the national program managers of
                  environmental and management responsibilities  (e.g., the
                  Superfund Amendments and Reauthorization Act Title
                  HI facility files) and working copies of many other records.
                  Additionally,  the national records management program
                  staff who oversee EPA's records management program are
                  located in OIRM.

            •     The regional offices are responsible for maintaining large
                  volumes of official Agency records, including records of
                  general management functions needed  to support their
                  operations (e.g.,  budgeting information), Superfund site
                  files and Administrative Records, Resource Conservation
                  and Recovery  Act (RCRA) facility files,  and other media
                  program files, such as air, drinking water, and pesticides.
                  Regions also maintain  working copies of documents, such
                  as grants and  contracts, whose official copies  are held in
                  headquarters.

            •     EPA's laboratories maintain information collected and
                  analyzed by research programs in support of the Agency's
                  legislation and regulation.  This  documentation includes
                  raw data, research analysis reports, computer models,
                  guidance and  technical reports.

            The national records  management program (NRMP) staff in
      OIRM provide overall authority and leadership to records managers in
      headquarters offices,  regional offices, and  the  laboratories. As the
      national program manager, the NRMP is responsible for the following:

            •     Develop, revise,  and modify Agencywide policy,
                  procedures, and guidance

            •     Handle negotiations with NARA on  Agencywide issues

            •     Provide expertise to program and management offices to
                  assist them with records management issues; this
                  expertise includes the  development and conduct  of
                  Agencywide training programs for managers and records
                  staff

            •     Conduct evaluations of EPA's records management
                  program.
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                                                  Records Management  Program
            Consistent  with  Agencywide  policy  and  guidance, the
      headquarters offices, regional offices, and laboratories:

            •     Implement Agencywide policies by tailoring the NRMP's
                  procedures and guidance to fit the particular needs of their
                  organization

            •     Develop additional policies, procedures, and guidance
                  documents where necessary to support operations in their
                  offices

            •     Perform records management program planning, both
                  strategic and tactical, and budgeting for the individual
                  office, region, or laboratory

            •     Arrange for the provision of records management
                  services (i.e., file plans, file maintenance, records
                  retirement) to their users either directly, through contract
                  support, or through delegation to the programs

            •     Perform training of managers and records staff

            •     Assist the NRMP through review of materials, such as
                  new policies, disposition schedules, etc., arid by providing
                  input on various records management issues

            •     Conduct evaluations of the individual office,  regional or
                  laboratory records management programs.

            Similar responsibilities are held by media  program  offices
      and/or divisions  within a  regional  office.  These  responsibilities
      include:

            •     Developing local policy, procedures, and guidance

            •     Planning for  the program

            •     Notifying appropriate regional records management staff
                  about new types of records as they are created

            •     Providing direct support for records  management, unless
                  these responsibilities are contracted out.

      The  interaction of these  various parties - headquarters offices, the
      regions,  and  the laboratories  - allows EPA to fulfill  the records


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Records Management  Program
      management requirements outlined by the federal government and to
      satisfy the unique requirements dictated by the Agency's mission and
      the records life cycle.

      5.  Organization and Staffing	

            The regional  offices need  clear  accountability for records
      management in an organization and staff that can productively focus
      all regional records management activities.

            Organizational Structure

                 The January 17,  1989, Memorandum from the Director,
            OIRM,   "Revised Regional Information Resources Management
            Model to Include Records Management Support," recommends
            that the Assistant Regional Administrator assume responsibility
            for a regional records program. The model places the program
            under the direct supervision  of the  IRM branch chief.  (See
            Appendix A.) The organizational structure must facilitate close
            relationships between the records management program and the
            various  media programs and general management offices. The
            organizational structure illustrated on the following page is one
            approach to  meeting  both of these  criteria. This  structure
            emphasizes the  need for ongoing liaison among all regional
            managers with responsibilities  for records.   It also reflects  how
            several regional  offices are beginning  to organize their records
            management program.

                 This organizational structure provides a direct  line of
            authority from  the Regional Administrator and  Assistant
            Regional Administrator's offices  through  the IRM  Branch to
            responsible managers in each major organization of the regional
            office.   The specific organizational structure will need to be
            determined by the individual  regions  according  to the
            operational needs of their program or management offices and
            their available resources.

            Staff Roles and Responsibilities

                 The records management program will need to  be staffed
            with  individuals  who have  a  suitable mix of records
            management  expertise, technical skills, general management
            skills (staff management, contract management, budgeting, etc.),
            and interpersonal skills.  Based  upon these requirements, one
20             (November 1991 draft)           Model Regional Records Management Manual

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                                                 Records  Management Program
            approach to staffing is as follows (refer to the chart  on the
            following page for illustration):

                   •     Records Management Program Coordinator  - The
                        coordinator will be responsible for region-wide
                        records management policy, resource, and contract
                        decisions.  This position will report to the IRM
                        chief and will have oversight responsibility for the
                        regional records management program.
                        Additionally, this staff member will coordinate
                        with the program and  other management offices
                        through these offices' designated liaisons. Due to
                        the inherently governmental  functions required of
                        the Records Management Program Coordinator,
                        this  position must be filled by an EPA employee.
                        The  Information Specialist job classification series
                        would be appropriate for this position. A model
                        position description based on the NRMP  manager's
                        responsibilities is included in Appendix B.

                   •     Regional Records Officers - Regional records  officers
                        are accountable for the  ongoing daily
                        administrative oversight of the records
                        management operations directly supporting  their
                        organization.  There are several alternatives  for
                        establishing these roles; the most feasible one
                        reflects how the regional office is organized and
                        how much direct management for records is
                        exercised by the Records Management Program
                        Coordinator. The most frequent practice in EPA's
                        regional offices is to designate a records officer for
                        each major media program (i.e., Superfund, RCRA,
                        Air and Water) and for each general management
                        program (i.e., human resources, planning and
                        management, and financial management). The
                        records officers have functional lines  of
                      • responsibility and  communication linking them to
                        both the overall regional program through the
                        Records Management Program Coordinator and the
                        individual  media and general  management offices.
                        The records officers positions may be fulfilled by
                        either EPA or contractor staff.  If fulfilled by a
                        contractor, the Records Management Program
                        Coordinator must ensure that an EPA staff member
Model Regional Records Management Manual           (November 1991 draft)              21

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Records  Management  Program
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                                                 Records Management  Program
                        from the media or general management office is
                        designated as the official liaison to ensure
                        accountability for services.

                        Records Management Staff - The number and types
                        of records managers and records clerks required will
                        depend upon the types of services to be performed,
                        the volume of records to be managed and the
                        location of records holding and storage areas. In
                        general, each region will need a variety of records
                        managers with supervisory responsibilities to
                        oversee daily operations of filing, using and
                        maintaining records by records clerks.  Regular
                        housecleaning and disposition activities are
                        scheduled and supervised by the records managers.
                        Depending on the organization and size of the
                        records management program, all supervisory
                        activities may be fulfilled by the records officers in
                        each office rather than delegated to supervisory
                        records management staff. All records
                        management staff positions may be filled by
                        contractors.
      6. Records Center Concept
            One management and  organizational  model  for serving
      regionwide records needs with accountability and leadership is through
      a Regional Records Center. The basic management objective of such a
      center is to facilitate access to and preservation of recorded information
      of value, to regional managers and staff.  Organizationally, the center
      serves as a single source of policy, guidance, and communication for an
      integrated regional  records  management .program  directed  by a
      Regional Records Management Coordinator.  Physically, the center  can
      be located in one consolidated space, for example, adjacent  to  the
      regional library and information center, or  in a variety of satellite
      centers near  the media and  general management offices they serve.
      Whether housed in one or several locations, the centers must serve as
      custodians of EPA records and advisors to owners  and users  of EPA
      records.

            An  example of  how  the records center concept might be
      implemented in regional offices may be instructive.  Several regional
      offices have, in fact,  already established records  centers  to meet
      regulatory and  court requirements for the Administrative Record and
Model Regional Records Management Manual           (November  1991 draft)              23

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Records  Management Program
      other Superfund  program documentation.  Assistant  Regional
      Administrators may wish to build upon this foundation by establishing
      record center operations for general management functions, many of
      which are under the ARA's span of supervision. The regional records
      management program could be further expanded by taking advantage
      of regional manager's initiatives to improve their operations as well as
      opportunities  presented by office relocations and  new  program
      developments.  Under  the leadership  of  the  Regional Records
      Management Coordinator, regional records officers could be appointed
      and record center operations could be established in an  incremental
      manner  to  include all regional program and  general management
      offices.

            A successful center will address the following requirements:

            •      Documents must be managed with integrity throughout
                  their active life cycle to satisfy chain of custody
                  requirements

            •      Regional staff must be able to obtain the necessary
                  documentation

            •      Regional-staff must receive reliable advice in meeting
                  their individual records management needs.

      To meet these basic objectives and requirements,  a Regional Records
      Center must offer  not  only records management knowledge  and
      expertise, but also an understanding of the regional management and
      programmatic requirements.  This knowledge will allow the records
      center  to provide  an operational capability  which will support
      performance of the various programmatic or administrative activities
      necessary to achieve EPA's mission. The specific charter of the Regional
      Records Center will be influenced by the particular needs of the region.
      7.  Functions and Services	

            The records center or centers should facilitate and support the
      management of regional records throughout their life  cycle.  Owners
      should  have confidence they  are  complying  with  legislation  and
      regulation as well as the best practices in the field.  Users should have
      confidence they can identify and obtain recorded information needed.
      to perform their work. In order to accomplish this, the records center
      should be under  the functional supervision of  the Regional Records
24             (November  1991 draft)          ' Model Regional Records Management Manual

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                                                 Records  Management  Program
      Management Coordinator and managed on a  day-by-day basis by
      regional records officers. It should perform  the following primary
      functions and services for the region (as illustrated in the exhibit on
      the following page):

            •     Organize documents  by tailoring NRMP guidance on file
                  plans and schedules to the region's need and providing
                  expertise to owners in records inventory and creation of
                  disposition schedules

            •     Dispose of documents by carrying out the disposition
                  schedules with the owner's approval

            •     Provide reference and referral services to help  users,
                  including the general public, obtain  documentation and
                  keep owners informed of developments in records
                  management, such as vital records and electronic
                  recordkeeping

            •     Complete administrative management activities,
                  including regional policy, planning, staffing, budgeting,
                  training, and  contracting.

      These functions encompass many of the records management program
      activities discussed in Section in. Execution of these functions involves
      the  records center staff  working  with program and  general
      management staff to determine specific implementation requirements
      and procedures.

            Organize  Documents

                  To effectively organize  records, the records  center staff
            should first confer  with the program or  general management
            staff to learn their specific  needs  in this area, such as the
            following:

                  *•     Information on the types and  volume of official
                        records that the program or administrative staff
                        would like to be maintained by the records center
                        (as determined from the records inventory
                        conducted by program or administrative staff)
Model Regional Records Management Manual           (November  1991 draft)             25

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  Records Management Program
        Records  Centers  Functions  and  Services
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(November 1991 draft)
Model Regional Records Management Manual

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                                                  Records Management  Program
                   •     Any file plans, policies, procedures, or standards
                         that are already being used to structure individual
                         files

                   •     The most effective manner of organizing and
                         indexing the various files (e.g., alphabetically by
                         facility or other appropriate category, by EPA ID
                         number, by activity)

                   •     Any records that require special/separate
                         organization and handling, such as Confidential
                         Business Information  (CBI) or enforcement-
                         sensitive records

            Records center staff should then incorporate  these requirements
            into classification schemes which will be used to organize, index,
            and file documents in the records  center. To promote efficiency
            in the ongoing organization of records, the  records center staff
            should also develop specific procedures defining the appropriate
            condition of the records  entering the  center and  the  labeling
            information  that  must accompany all new records.

            Circulate and  Control  Documents

                   After  organizing the files, the records center staff will be
            responsible  for  overseeing the circulation  of  the records to
            program, administrative  staff, or the public, if applicable. This
            process will require the development of detailed procedures to
            guide:

                   •     Searching for and retrieving requested records

                   •     Check in and out, including authorization
                         information

                   •     Tracking records, including monitoring time
                         limitations and sending late return notifications

                   •     Pickup of records from program/administrative
                         staff

                   •     Assistance in research on what is available.
Model Regional Records Management Manual           (November 1991 draft)              27

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Records Management Program
            As with the organizational function, the records center staff will
            need to work with the program or administrative staff to obtain
            information necessary to develop the procedures, such as what is
            an appropriate  time period for records to be checked out; who is
            authorized to check out the records; how often should records be
            picked up from the staff; whether originals or duplicates should
            be circulated,  etc.   Records  center staff  will also  need  to
            determine the most appropriate vehicle through which  the
            center's users can be trained in the circulation procedures.

            Records  Disposition

                  The records center staff will also assist the official record
            owners - program  or  general management  staff -  with  the
            disposition of records. This responsibility will involve:

                  •      Sending and retrieving records from the Federal
                         Records Center (FRC)

                  •      Destroying records, where appropriate

                  •      Transferring records to  the National Archives.

                  Execution of this function will require an  especially dose
            working relationship with the program or management office to
            identify records which do not need to be regularly  accessed and
            can,  therefore,  be sent to the FRC. Regional staff input will also
            be essential to  ensuring that official records  are either correctly
            destroyed or archived. The key role of the  center is  to relieve
            regional staff of the processing work involved in retirement and
            archiving.

            Reference  and  Referral

                  Another important service offered by the records center is
            the ability  to  provide reference  and  referral  assistance.  This
            service can be offered not only internally within EPA but also to
            members of the public who are requesting access to the Agency's
            records.  Records center staff will be available to help individuals
            identify and  locate records,  and  if  the  information is  not
            maintained  within the particular facility, to refer  the requestor to
            the appropriate location, such as the regional library.  Provision
            of this service begins to bridge the gap between a records center
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                                                Records Management  Program
            whose sole function  is to house  records  and an  integrated
            information service center.

            Administrative  Management

                  The final function of the records center is to expand on
            NRMP  policies  and  guidelines  for  Agencywide  records
            management to meet the specific needs of their  regional office.
            Administrative management involves all the activities required
            to promote and support administrative decisionmaking. For
            example, the records center  should track statistics on  the overall
            volume  of records maintained  and  the circulation and disposal
            activity  required to  support  the  activities of  the  particular
            program or administrative office.  These statistics will support
            the budgeting and planning processes in both  the -individual
            program or administrative office and the  ARA's office.  For
            example, workload statistics  will  assist the records  center
            manager in  determining  the numbers and types of staff
            members and equipment which will be needed  within the
            center.   Another component  of administrative management
            involves evaluating  the  activities  of  the  records  center to
            identify areas where  improvements may be necessitated and
            potential approaches to achieving these improvements.

      8. Career Growth and Development	

            The effectiveness of  EPA's  records management  program
      depends upon the performance of staff fulfilling these functions.  In
      the public and private sector, records managers are generally found
      organizationally placed at the mid-management  level. This reflects the
      level of experience, knowledge, and skills required to carry out  records
      management functions.

            In EPA's regional offices, accountability for records management
      should be reflected in positions with supervisory,  policy, liaison and
      contract  management responsibilities. Appendix B of  this  document
      includes a position description under  the Information Management
      Specialist series  for the NRMP  manager  in  OIRM.  This position
      description serves as a model for the comparable regional position of
      Regional Records  Management Coordinator.  The primary functions of
      this position are to develop, implement and administer the region's
      records management program in accordance with policies established
      by the NRMP, including the organization, retention, protection, and
      disposition of Agency records.
Model Regional Records Management Manual           (November  1991 draft)             29

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Records Management  Program
            The supervisory, policy and contract duties of this position can
      only  be fulfilled by  an  EPA employee. The Regional Records
      Management Coordinator, or equivalent functional position suited to
      the region,  may  manage records  supervisors  and staff who  are  a
      combination of EPA and contractor staff.

            Many of the records officers  in regional  program and general
      management offices perform line management responsibilities.  These
      records officials coordinate their responsibilities through the functional
      supervision  and  guidance  of the Regional Records  Management
      Coordinator.  They organize records in  their responsible office and
      develop efficient operating methods and  procedures.  They train and
      delegate responsibilities to other staff, manage appropriate supplies and
      equipment, and continuously monitor the  quality of records services.

            Qualifications  for staff performing records  management
      activities under the supervision of these two managerial positions vary
      by the nature and volume of records in  each regional office.   While
      many daily  tasks  can be performed by a records  clerk, key functions
      such  as records  inventory  and  classification  require additional
      expertise. The complexity of regulatory requirements for documents
      also increase the  skill levels needed by records staffs, such as those
      governing the Superfund program's Administrative Record.

            In general,  regional records management programs need staff in
     ' management, line-supervisor and operating personnel  positions.

            Opportunities for training and career growth  are critical for
      continued  productivity and  responsive service.  Records officers,
      managers and staff benefit from training to establish and develop their
      professional  expertise.   In addition to  maintaining knowledge of
      applicable federal and  EPA policy and guidance, records managers
      require increasing expertise in the following areas:

            •     Records inventory

            •     Files management

            •     Records disposition schedules (development and
                  implementation)

            •     Document indexing and retrieval systems

            •     Litigation support


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                                                 Records Management  Program
            •     Vital records programs

            •     Inactive records storage

            •     Historical documentation

            •     Forms and records management

            •     Public access.

            A recurring theme in records management is the application of
      information technology to improve  the  integrity of and  access to
      recorded information.  Many records  management professionals are
      acquiring  the  technical  skills  to   manage  information  more
      productively in electronic form, especially with image processing, text
      retrieval and computer-aided retrieval (CAR) systems.

            Membership in professional associations should be encouraged
      to promote  continuous  professional  development.   Professional
      records management  associations also provide extensive training
      opportunities in addition to those provided by federal agencies.  The
      General Services Administration (GSA),  the  National Archives  and
      Records Administration (NARA) as well as the U.S.  Department of
      Agriculture's Graduate School offer courses targeted to the professional
      records officer.  A list of major professional associations to  check for
      training is provided later as an attachment to Section in.9.

      9. Planning	

            To effectively  develop,  implement, and  maintain a records
      center, a regional office must:

            •     Perform ongoing strategic and operational records
                  management planning

            •     Ensure that planned activities are  implemented in an
                  appropriate, timely manner.

      These two  planning and implementation  issues will be  discussed in
      the following sections.

            Planning for the records center should take two forms:  strategic
      and operational. Strategic planning involves the process of considering
Model Regional Records Management Manual           (November  1991 draft)             31

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Records Management Program
      overall regional record management objectives and needs in the long
      term and establishing a long-range plan which will allow the records
      center to evolve and to reach these objectives.  Operational planning
      covers a  shorter  time  frame and involves  the  specific,  detailed
      planning required to accumulate the staff, space, equipment, materials,
      and procedures necessary for a records center to operate.

            There are several issues that a region ought to consider when
      performing either  strategic  or  operational  records management
      planning:

            •     Planning should be ongoing, rather than on a project by
                  project basis, to ensure that the records center continues to
                  evolve and to operate successfully.

            •     Individuals at a variety of levels and from many
                  organizations within the regional office need to be
                  involved in the records management planning process
                  (i.e., records center staff, program and administrative staff,
                  IRM staff, the RA and ARA's offices).

            •     EPA's long-range  goals and priorities (as described in the
                  IRM Strategic Plan and program office strategic plans) and
                  their impact upon records management should be
                  considered.  For example, the Agency's IRM goal of access
                  to integrated environmental information influences
                  strategic records management planning.  This goal
                  envisions functional  integration of services provided
                  today to the regional libraries, records programs, and
                  information centers.  It also urges records mangers to
                  evaluate how advanced information technologies provide
                  integrity of and access to Agency records.

            The performance of the records center will need to be reviewed
      and  evaluated annually so that  this information can be used as  an
      input to both strategic and operational planning.

      10. Budgeting	

            The  primary  budgeting objective for the records  center  is to
      provide recurring resource support for the center, rather than funding
      on a project by project basis. To accomplish this regional managers
      need to consider:
32             (November  1991 draft)           Model Regional Records Management Manual

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                                                Records Management  Program
            •     EPA's budget process and cycle

            •     Records management needs, in terms of equipment,
                  space, materials, staffing, etc.

            •     Available resources.

      Each of these budgeting topics will be discussed in turn.

            EPA's budget process  is  linked  to  the Agency's  planning
      processes. The issuance of the Agency's Operating Guidance in October
      establishes the priorities and resource parameters that will influence
      how the  budget  is constructed to carry out the Agency's plans.  The
      major cycle of budget activities are:

            •     February to May — preliminary development of resource
                  levels needed to meet program commitments

            •     May to early July — the Office of the Controller's budget
                  call  letter in May provides detailed guidelines for
                  submission of budget requests, usually due the first week
                  of July

            •     July to early August — the Office of the Controller holds
                  reviews during which the Administrator determines the
                  Agency's requests and issues passbacks of decisions and
                  addresses appeals on these decisions

            •     September — EPA's budget request is submitted to the
                  President through  the Office of Management and Budget
                  which submits the  President's budget for Congressional
                  review  and approval.

            In  the budget process,  EPA managers are requesting resources to
      implement programs and initiatives  a year or two  in the  future.
      Successful  budgeting for regional  records  management programs
      requires careful advance planning.

      11. Records Management Needs	•

            This section  provides information on  records management
      needs  that  should  be  considered  when   budgeting  for  the
      implementation and maintenance of a records center or centers.  There
      are two types of  costs that will  need  to be considered when budgeting
      for the near-term support of the regional records center:
Model Regional Records Management Manual           (November  1991 draft)             33

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Records Management Program
            •   .  Start Up Costs — Start up costs are those costs associated
                  with the initial implementation of the records center,
                  such as equipment, office furniture, and facilities
                  modifications. These costs need to be budgeted for only
                  once.

            •     Operational Costs — Operational costs are those costs
                  associated with the ongoing support and maintenance of
                  the records center, such as supplies, storage space, and
                  monthly maintenance for equipment.  These costs need  to
                  be budgeted for on a continual basis.

      Both types of costs will  be  covered in detail in this section.   More
      strategic planning on EPA's records management program needs in the
      future for equipment, space, and  other resources could  change this
      discussion substantially.

            As defined above, start-up costs  are those costs associated with
      the implementation. Below is a discussion of some one-time costs.

            •     Facilities Modifications - The space that will house the
                  region's records center or centers may need to be modified
                  in order to promote a safe  and efficient environment.
                  Some of the modifications which need to be considered
                  during budgeting are:

                         Smoke" detection systems
                         Sprinkler  systems
                         New or improved lighting systems
                  - •     Fire extinguishers.

                  The costs of such systems may vary depending on the
                  facilities being modified and the state of the technology
                  being employed.  One important consideration in the
                  design and cost of records facilities is the floor  load
                  capacity for the volume of records. Many records centers
                  are placed in basement space on the concrete foundation
                  because the weight of the records cannot be carried by the
                  building.  The floor load capacity is generally estimated by
                  multiplying the total cubic  volume of records by 3.5
                  pounds per cubic foot. Then divide the total weight by the
                  square feet the records will occupy to calculate the
                  estimate.
34             (November  1991 draft)           Model Regional Records Management Manual

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                                                 Records Management Program
                  Additional modifications may be needed to secure CBI
                  and other sensitive information.

                  Computer Equipment - The start up costs for a new
                  records center may include estimates for hardware' and
                  software components which will be used in the
                  classification, circulation, tracking, and disposition of
                  records.

                        Hardware - Hardware costs may vary greatly from
                        vendor to vendor, and they may  change over  time.
                        Therefore, current component costs should be
                        verified before estimating total cost. If appropriate,
                        leasing or lease-to-purchase options should be
                        considered.  Hardware prices should also include all
                        costs involving component installation, power and
                        cabling (if appropriate), and documentation.

                        Software - Software costs should include all the
                        required system and application software, and any
                        software licensing or maintenance fees.

                  Office Furniture - The records center will need to be
                  furnished in accordance with its users' needs.  The center
                  will need, at a minimum:

                        Desks
                        Tables
                        Chairs
                        Filing units for standard and nonstandard files
                        (e.g., maps and photographs)
                        Sorting units.

                  The following policy requirements and standards should
                  be adhered to when ordering filing units.

                        In  accordance with EPA policy, filing equipment
                        and supplies acquired for use within the Agency
                        will be the most economical possible to meet filing
                        requirements. Filing equipment is not to be
                        requested solely to improve appearance, office
                        decor, status elevation, nor because of a desire for
                        the latest design. Used or reconditioned equipment
                        will be used when available. As equipment
Model Regional Records Management Manual           (November 1991 draft)              35

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Records Management Program
                        becomes excess to local needs, it must be turned
                        into the Property Office for further disposition.

                        -Standard equipment lisTed in the GSA Stores Stock
                        Catalog and/or the Federal Supply Schedules
                        should be used in preference to nonstandard items,
                        unless there is a requirement for a special files
                        operation.  Letter-size equipment should be used in
                        lieu of legal-size equipment unless there is a
                        specific requirement for legal-size filing equipment.

                        Shelf filing equipment is less expensive than file
                        cabinets, requires less space, and facilitates filing
                        operations.  Standard shelf filing may be more
                        appropriate than  filing cabinets for records that are •
                        alphabetically or numerically arranged, such as case
                        or project files. Shelf filing should be used when
                        records total 50 cubic feet or more and when:

                        ••    The purchase of new filing  equipment is
                              contemplated

                        ••    Additional space for filing operations is
                              required and only a limited amount of space
                              is available

                        ••    The filing station is  in a relatively
                              permanent location.

                  More information on filing unit  requirements, requesting
                  filing units, and utilization of filing units can be found in
                  Section 5  of the EPA  Records Management Manual.

                  Records Center Equipment - The records center will  need
                  to be-equipped with certain devices to facilitate access to
                  files and duplication of files. Examples of such equipment
                  are:

                        Ladders - Pulpit type ladders of light wood or  metal
                        construction are economical and practical.
                        However, to provide the greatest degree of safety,
                        handrails should be added to at least one side of the
                        ladder.
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                                                  Records Management  Program
                        Carts - Carts are used for the retrieval and
                        interfiling of documents. Many different types of
                        carts are available, but one which will allow the
                        stacking or placement of documents (one behind
                        the other) without allowing them to slide off, will
                        be the most practical.  The tray size of the cart may
                        vary, but the cart should be about waist high to the
                        user (approximately 32 inches).

                        Hand Truck - Heavy cartons containing documents
                        may need to be moved.  Hand trucks can easily
                        move stacked  cartons from one location to another.

                        Scaffolding - Scaffolding equipment is useful when
                        large volumes of cartons are being placed onto
                        shelving. Scaffolding equipment eliminates
                        numerous ascents and descents of a regular ladder.

                        Duplicating Equipment - The records center will
                        need to have available to it equipment to make
                        copies of records for internal EPA and public use.

            •     Space - The records center or centers will require floor
                  space to store or shelve records as well as space for staff
                  and facility functions.  Facility functions may include
                  reading desks, conference rooms and public access
                  accommodations..

            •     Human Resources - A great deal of the initial costs
                  associated with a regional records center will result from
                  the need for human resources.  Staff will be needed to
                  convert and classify records, organize and shelve files,
                  install and configure equipment, and for a variety of other
                  tasks. When budgeting, regional  managers should plan
                  for at least one EPA management position, as well as for
                  line supervisors and operating personnel.

            As  defined previously,   operational  costs are  those costs
      associated with the support and  maintenance  of a records center.
      Below is a discussion of some common operational costs.

            •     Monthly Maintenance for Equipment - The proposed
                  model regional records  center  will be semi-automated,
                  therefore budgeters will need to include costs for monthly
Model Regional Records Management Manual           (November  1991 draft)              37

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Records Management Program
                  maintenance of computer and duplicating equipment in
                  their operational budgets.

            •     Records Center Supplies - Records centers will need to
                  maintain and replenish certain types of supplies on a
                  continual basis. Three major supply categories are:

                        Storage Supplies -  Records centers  will need to
                        maintain an ample supply of cartons, labels, folders,
                        tape, and markers, for packing and labeling inactive
                        files.

                        Desk Supplies - Records center personnel will need
                        an adequate amount of desk supplies such as paper,
                        pens, staples, etc.

                        Equipment  Oriented Supplies - Records centers will
                        need to keep.a supply of toner, paper, and cartridges
                        on hand for computer and duplicating equipment.

      12. Use of Contractors	

            The objective of this section is to assist regional managers in the
      contract  management  process through providing  them  with overall
      guidance on how to best utilize contractors in records management.
      Contractors may be used during the development and maintenance of
      a records center to:

            •     Conduct records inventory

            •     Develop file structures

            •     Provide overall administration of the records center once
                  it is established.

      At  EPA  there  are  three key positions  associated with the  contract
      management process.  They are the Contracting Officer (CO), the Project
      Officer (PO), and the Delivery Order Project Officer (DOPO). Mid-level
      EPA staff will usually serve as DOPOs on EPA mission contracts.  The
      duties of these contract positions are outlined below.

            •     Contracting Officer - The Contracting Officer is the only
                  individual within EPA who has the authority to bind the
                  Agency in a formal, contractual agreement.
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                                                 Records Management Program
            •     Project Officer - The Project Officer provides general   .
                  supervision of the contract. The Project Officer's
                  responsibilities are authorized by the Contracting Officer.

            •     Delivery Order Project Manager - The DOPO is responsible
                  for daily contract management, providing technical
                  direction, and monitoring costs.

      For more information about the responsibilities of these  individuals,
      refer to Chapter 7 of EPA's Contract Management Manual, the Federal
      Acquisitions Regulations (FAR), and the Project  Officer's Handbook.

            Information on how to  manage  contractors  during  the
      implementation  and  support  of  a  Regional records  program  is
      provided in the  following text  in  terms of problems that can  arise,
      prohibited contracting activities, and initiation and management of
      contracts.

            •     Problems that can arise during contract management -
                  Occasionally, abuse of government  contracts does occur.
                  Such abuse may  be caused by unclear direction from EPA
                  or as a result of contractor misconduct.  Several examples
                  of contract abuse are presented below.

                        Contract abuse can occur during the identification
                        of the Agency's need for goods or services if the
                        Agency:

                        • •    Purchases goods or services in excess of what
                              is needed

                        • •    Does not clearly define the goods or services
                              needed, permitting the contractor to provide
                              more than, or other than, what is actually
                              needed

                        ••    Purchases goods or services that the
                              government already possesses.

                        Contract abuse can also occur during the
                        development of the Statement of Work  (SOW)  if
                        the Agency:
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Records Management Program
                        • •    Fails to provide a clear SOW that will allow
                              the contractor to work independently
                              without day-to-day interaction with the
                              DOPO.

                        ••    Divides delivery orders into smaller sections
                              in order to circumvent certain degrees of
                              review or approval.

                        Contract abuse can occur when the contractor
                        improperly charges the Agency for goods or services
                        provided. Common examples of improper charges
                        are:

                        • •    Work done for one  contract, but charged to a
                              different contract

                        ••    Work done by junior level staff, but charged
                              at senior staff rates

                        • •    Work or services provided to the Agency
                              that the contractor can use in other work
                              assignments.

                  In order to prevent such abuses and to ensure that the
                  Agency receives the level of service for which it pays,
                  careful attention must be paid to all phases of contract
                  management.

            •     Prohibited contract activities - The federal government
                  and the EPA have identified certain types of activities
                  which present a conflict of interest dilemma for
                  contractors. These conflicts may be either organization or
                  personal in nature. Organization conflicts of interest
                  involve the recommendations of one delivery order
                  directly affecting the position of the contractor on another
                  delivery order or in general. Personal conflicts of interest,
                  on the other hand, involve a member of  the proposed
                  work assignment team being affected personally (e.g.,
                  through stock ownership) as a result of the outcome of a
                  delivery order. In order to prevent both types of conflicts
                  of interest, the federal government and EPA have
                  assembled a list of activities from which contractors are
                  prohibited while under contract  to the Agency. The list is
                  provided on the next page.


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                                                 Records  Management Program
                  Initiation and management of contracts - Although
                  contractors may play an essential role in the
                  implementation and support of a Regional  Records
                  Center, it is important to remember that many services
                  are already available through existing EPA contracts.
                  There are four delivery order contracts which may prove
                  especially useful. They are:

                        Labat-Anderson Incorporated (LAI) — This contract
                        provides comprehensive support services for
                        libraries, dockets, public information centers, and
                        records management.  For more information,
                        contact Linda Garrison, OARM/OIRM at FTS 260-
                        6939 (email L.Garrison).

                        Technical Operational Support Services (TOSS) —
                        This facilities management contract is awarded to
                        Computer Services Corporation (CSC) for
                        operational and technical support in the areas of
                        hardware and software maintenance,
                        data/information center operations, data entry
                        operations, training  programs, hotline operations
                        and microform services (micrographics,
                        microfilming and microfiche).  For further
                        information contact Patrick A.  Garvey,
                        OARM/OIRM at FTS 260-2381  (email P.Garvey).

                        Office of Administration Research Management
                        (OARM) — General  management and information
                        resources management analysis support are
                        available from American Management Systems,
                        Inc. (AMS) and from Booz, Allen and Hamilton,
                        Inc. For further information contact Vicki Bailey or
                        Adrianna Fortune, OARM/OA at FTS 260-5000
                        (email V.Bailey or A.Fortune).

                  There may be circumstances, however, in which these
                  contracts will  not be able to provide the necessary services,
                  and a new work assignment will need to be initiated.
                  Appendix B provides a list of Do's and DonTs for contract
                  management.  The list begins with the initiation of a
                  contract and progresses through the various stages of
                  contract management.
Model Regional Records Management Manual          (November  1991 draft)              41

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Records Management Program
         i

            5.


            6.
      PROHIBITED CONTRACTING ACTIVITIES AT EPA

1.    Preparing Congressional testimony.

2.    Interviewing or hiring of individuals for employment at
    . EPA or developing Position Description and Performance
     Standards.

3.    Determining Agency policy.

4.    Participating as voting member on a performance
     evaluation Board; participating in and/or attending Award
     Fee Meetings; preparing Award Fee letters, even under
     typing services contracts; preparing Award Fee Plans.

     Preparing documents on EPA letterhead other than
     routine administrative correspondence.

     Reviewing vouchers  and invoices for the purposes of
     determining whether costs, hours, and work performed are
     reasonable.

7.    Preparing Statements of Work, Work Assignments,
     Technical Direction Documents, Delivery Orders, or any
     other work issuance  document under a contract in which
     the contractor is performing or may perform.

8.    Preparing responses  to audit reports from the Inspector
     General,  General Accounting Office, or  other auditing
     entities.

9.    Preparing responses  to Congressional correspondence.

10.   Preparing responses  to Freedom of Information  Act
     requests  other than routine, non-judgmental
     correspondence.

11.   Participating in any contract  which authorizes a  contractor
     to represent itself as  EPA to outside parties.

12.   Conducting administrative hearings.

13.   Reviewing findings concerning  the eligibility of  EPA
     employees for security clearances.

14.   Preparing an officer's official budget request.
42
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     III. RECORDS  MANAGEMENT
           PROGRAM  COMPONENTS
     1.    Records Inventory

     2.    Records Classification/File Plans

     3.    Document Control

     4.    Records Disposition

     5.    Vital Records

     6.    Information Security

     7.    Accommodating Public Access Requirements

     8.    Electronics Records Management Technology

     9.    Regional Staff Communication
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                                                               Records  Inventory
       1.  RECORDS INVENTORY
             In order to effectively manage records, regional offices must first
       conduct a file inventory.  A file inventory is a complete cataloging of a
       region's current records created and used by regional staff. The records
       inventory assesses the functions and activities  of regional records for
       classification purposes, and  is  therefore  the first phase in  the
       development of a regional records  management program.

             Objective

                   The  objective  of a records inventory  is  to provide  a
             complete and accurate summary of a  region's file holdings; it not
             only identifies but also  quantifies all of  the  records that  are
             created and maintained by  the region. The categories derived
             from   the  records  inventory  provide   the  foundation  for
             structuring the procedures discussed  in the following sections.

             Legal/Administrative  Requirements

                   The list  below highlights  the  major legal/administrative
             requirements  for  records inventory with which  the regional
             offices must comply.
                         LEGAL AND ADMINISTRATIVE REQUIREMENTS
                          FOR INVENTORY OF RECORDS HOLDINGS
                 Freedom of Information Act
                 Superfund Administrative
                  Record Guidance
                 EPA FOIA Manual
                 General Federal Guidelines of
                 44 U.S.C. 3101-07,41 CFR 101
 Mandate the existence of an
 inventory of existing record series to
 facilitate access and accommodate
 public information requests

Guidance in implementing the Act and
limited Agency-specific guidance
exists to assist Regions in
conducting a Regional file inventory
Activities of the Agency must be
documented and records maintained
Model Regional Records Management Manual
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Records Management  Program  Components
            Approach

                  The following comprise the basic steps in initiating and
            performing a records inventory:

                  •     Define Organizational Mission^

                  •     Obtain  Management Commitment

                  •     Assess Current Document Management System

                  •     Select Personnel to Conduct the Inventory

                  •     Review Other Records Management Systems

                  •     Understand Major Categories of Records

                  •     Prepare Inventory Survey Form

                  •     Conduct Preliminary Survey

                  •     Perform Records Inventory Survey

                  Define  Organizational  Mission — The  first step in
            conducting a records inventory is  to identify and document the
            goals and functions  of the organization, as well as its records
            management objectives.  These  objectives may  include the
            following:  to  archive official  records, to increase  productivity
            and effectiveness, to support auditing and litigation functions,
            and to facilitate document access and retrieval.  The purpose of
            defining the organization's mission  is  to guide  the records
            inventory staff in categorizing the regional file  holdings by
            function. These same categories will later serve as a basis for the
            file classification structure.

                  Obtain Management Commitment — The records officer
            should  obtain  written  commitment  from EPA  management
            (e.g., division directors),  giving the authority to proceed with the
            records inventory process.  A directive to middle management
            should be issued, stating the objectives, goals and  strategies of
            the records inventory and  requesting  the cooperation  of all
            concerned parties.  Finally, a memorandum should be sent to all
            supervisors and personnel concerned, identifying the  nature of
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                                                            Records Inventory
            the project and stating how the project will affect the work
            presently being done and when it will begin.

                  To facilitate further  communication, the records officer
            should  meet  on  a  regular  basis with  various  levels  of
            management.  It is  recommended  that  the records  officer
            participate in the  regular meetings  of Branch Chiefs, Section
            Chiefs, and so on. If possible, an orientation session for  all
            affected employees should be scheduled.  The topic of Regional
            Staff Communication is discussed later in Section ni-9.

                  Select  Personnel to Conduct  the  Inventory — It is
            recommended  that each  region  assemble  a  project team
            consisting of'EPA staff and/or contractors to perform the records
            inventory.  EPA staff must assist the contractors throughout the
            process by  furnishing  information about  the  records (e.g.,
            program-specific requirements)  which may not be immediately
            evident.

                  Review Other Records Management Systems — In order
            to benefit  from previous  records  inventory efforts,  records
            management systems  used in  regional  offices  should  be
            reviewed.  Adapting  components  from  existing  records
            management  systems  (i.e., file classification schemes, current
            storage techniques) could save considerable time and resources
            in performing records management functions.

                  Understand  Major Categories of Records — The records
            officer, in concert with the relevant general  management  or
            media program director, should determine which categories of
            records will be studied in detail.  To this end, it is useful to assess
            the current  document handling and  records management
            systems in the context  of  the  region's critical functions.   By
            distinguishing different types  of  documents  based upon  how
            they are created and how they are  used, the characteristics of
            documents at various levels in the organizational hierarchy will
            provide  the  basic  information  for  constructing  a  file
            classification scheme.

                  In conducting the inventory, it is important to distinguish
            between  "records"  and "non-records" as defined  by federal
            regulation and policy.

                  •     Records - Any documentary materials, regardless  of
                       physical form or characteristics which is (1) made or


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Records Management Program  Components
                        received by an agency of the United States
                        Government under federal law or in connection
                        with the transaction of public business or (2)
                        generated by public or private organizations under
                        contract, grant or agreement in support of EPA's
                        mission requirements or administrative
                        responsibilities and which meet the following
                        criteria:

                              Have administrative (fiscal or legal),
                              programmatic, or historical (informational
                              or evidential) value

                              Evidence the organization, function, policies,
                              decisions, procedures, operations or other
                              activities of EPA or the federal government

                              Are preserved or appropriate for
                              preservation.

                  •     Non-records - U.S. Government-owned
                        documentary materials that do not meet the legal
                        definitions of records. These include extra copies of
                        documents kept only for convenience of reference,
                        stocks of publications and of processed documents,
                        and library or museum materials solely for
                        reference or exhibition.

                  •     Personal Papers - Nonofficial, or private, papers or
                        other documents which pertain solely to an
                        individuals' own affairs and do not relate to or
                        have an effect upon the conduct of agency business.

            In general, all documentary  materials, regardless  of  physical
            form, that have programmatic  value or which contribute to an
            understanding of EPA operations or decision-making processes
            are records.

                  Prepare Inventory  Form — Once the categories defined
            above  are understood, a records inventory form should  be
            created to reflect these categories.  The survey form will also help
            to determine  whether additional information  should  be
            gathered.  To begin,  the inventory form should  request the
            following information for each record series, or group of files
            classified according to common characteristics and purposes:


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                                                             Records  Inventory
                  •     Department or organization name

                  •     Name of the record series

                  •     Purpose or description of the record series

                  •     Dates of the records

                  ••     Linear measurement of the series; that is, the
                        number of feet that the series occupies in a  cabinet
                        or other housing unit

                  •     Physical description (site and color for paper
                        records, size of tape or disk for magnetic media)

                  •     Date of inventory,  name of contact, name of
                        inventory analyst.

                  Many regional materials are not records,  under federal
            and EPA definitions, and  require little more than the general
            physical  description described above.  Additional  information of
            the characteristics of records that directly support  EPA's mission
            should be further researched based upon the following criteria:

                  •     Document access concerns which documents are
                        accessed by users of the system and the type of access
                        required.  Some of  the issues to consider are:

                              Frequency of access: Is access to documents
                              frequent or seldom?  Does access vary over
                              time?

                              Speed of access: Length of time required to
                              access documents?

                              Single user or multi-user access:  How many
                              users will  need to access the same document
                              or set of related documents simultaneously?

                              Other access  characteristics:  Do access
                              characteristics change over time? Are the
                              accessed documents usually related?  If so,
                              how?
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Records Management  Program  Components
                        Document storage relates to the need to store
                        documents. Some of the issues which should be
                        considered are:

                             Storage quantity: What is the total current
                             document volume?  How many documents
                             must be stored? What is the annual growth?

                             Storage duration:  How long must
                             documents be stored? If documents must be
                             stored for a long time,  then the ability of the
                             storage media to  remain reliable over time
                             becomes an issue.

                             Storage mandate:  How long must the
                             documents be retained to satisfy the legal,
                             statutory and disposition requirements set
                             forth in the Agency records disposition
                             schedules? Do any of these requirements
                             limit the range of acceptable storage media?

                             Active or inactive documents: How long do
                             documents stay active?  Does access to
                             documents become very infrequent with
                             age?

                        Document distribution relates to the extent to
                        which documents must be delivered to multiple
                        points in the organization in order to facilitate
                        other tasks. Some of the issues that relate to this
                        requirement are:

                             Extent of internal and external distribution:
                             Is document distribution required?  How
                             many copies of the document are typically
                             distributed, both internal to the parent
                             organization and to  external organizations.

                             Type of distribution: Is the whole document
                             distributed, or is only a  portion of the
                             document necessary? Alternatively, is  it
                             necessary to distribute only data from the
                             document?  Are documents distributed in
                             groups or individually?
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                                                             Records  Inventory
                        Document control relates to the security and
                        accountability requirements for documents in the
                        system. Issues to be considered in this area include:

                              Security requirements:  How extensive are
                              security requirements for documents in the
                              system? Who sets the security
                              requirements? Are they sufficient as they
                              currently exist?

                              Document  accountability:  How extensive is
                              document accountability?  Do the documents
                              have intrinsic value if control of the
                              document is lost? Who sets the
                              accountability requirements?  Are they
                              sufficient as they currently exist?

                              Security for portions of documents or for
                              data from documents: Do different security
                              requirements exist for different parts of the
                              same document?  Is document level
                              security/accountability  required?

                        Document processing is the extent of document
                        flow, modification or use of the document in the
                        routine business of the organization.  If the
                        document goes through extensive review or
                        modification during the creation process, or if
                        routine business processes depend upon utilization
                        and modification  of the document, then document
                        processing is  involved. The following issues relate
                        to this requirement:

                              Single or multiple persons processing
                              documents: Are documents typically
                              processed by one person or by many?  Are
                              multiple offices involved? Is there a
                              specified sequence of document flow during
                              processing?

                              Internal and external document processing:
                              Are the documents reviewed or modified by
                              external organizations?  Are documents
                              processed in groups or one by one? Are
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Records  Management  Program  Components
                           documents processed concurrently?  Is there
                           a requirement that documents be processed
                           in a specified time?

                 Organizing documents into detailed categories based upon
           this information will help to define the functions of a region's
           file holdings and to develop a file  classification scheme and
           records retention and disposition schedules. The relationship
           between the records  inventory and other records management
           components can be seen graphically below. These records
           management activities also prepare the records for  integration
           into and management by the records center or centers.

                   Relationship Between Records Inventory
                 and Other Records Management Components
                  Recorded Information Supporting Staff
                     and Program Mission and Functions:
                  Official Records
                  Working Papers
                  Personal Papers
                         Forms
                         Publications
                         Reference Materials
                                  Records
                                  Inventory
                                                  Disposition
                                                  Schedules
   File Plan
52
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                                                           Records  Inventory
                  It is important to phrase carefully the wording of  the
            inventory  form so that it may be easily understood.  Technical
            data processing terms should be removed and specific references
            to documents (e.g.,  document acronyms,  form numbers, etc.)
            should be  used where appropriate.

                  Conduct a  Preliminary Survey - Upon completion of  the
            survey form,  the next step is to conduct a preliminary survey of
            file holdings.  The  following information is to be obtained
            during the preliminary survey:

                  •    The volume of records (in cubic feet)

                  •    The length of time it will take to complete a survey

                  •    The location of records.

                  Computing  the volume of records is  the first  step  in
            determining how long the document survey will  take and how
            many resources will be needed. A walk-through survey involves
            counting file  drawers and boxes and observing the layout and
            types of  records and  records  management practices. The
           -approximate   volume  of a  Region's  records  can then  be
            determined by converting the amount of file holdings into cubic
            feet (See Calculations  to Determine Records Volume on  the
            following  page.)  From  here, the  personnel  and  time
            requirements  necessary to complete the records inventory can be
            estimated.   On  average,  a  staff member  with moderate
            experience can survey about 1000 cubic feet of records per week.
            Factors  that  may influence  the inventory rate include the
            complexity, size, organization, and location of the file holdings.
            For example,  some programs may have  very large volumes  of
            similar files (i.e., NPDES permit files or  RCRA  notifications)
            which may only require an hour or two  for several hundred
            cubic feet of records.

                  When conducting a preliminary survey, it is important to
            identify all of  the region's records; including desk files, map files,
            reels of microfilm, photographic collections, computer files,  as
            well as the records held in  traditional file cabinets. The survey
            may also entail review of records held by  the program staff at
            their  work  location.  These are important  components   of
            documentation and will be included in the development of the
            records center as well. The use of a coding scheme which
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Records Management  Program  Components
                     Calculation of Volume of Records

    FILING CABINETS:       One letter-size drawer = 11/2 cubic feet
                              One legal-size drawer = 2 cubic feet

    FILING CASE:             One 3-by 5-inch case = 1 1/10 cubic foot
                              One 4-by 6-inch case = 1/4 cubic foot
                              One 5-by 8-inch case = 1/4 cubic foot

    SHELF FILES:             Letter-size 1 linear foot = 4/5 cubic foot
                              Legal-size,-! linear foot = 1 cubic foot

    TABULATING CARDS:    10,000 cards = 1 cubic foot

    OUTSIZED EQUIPMENT:  Inside cubic measurement

    MAGNETIC TAPE:        Seven reels = 1 cubic foot

    MICROFILM:             100 16 mm reels (100 feet) = 1 cubic foot
                               50 35 mm reels (100 feet) = 1 cubic foot

    MICROFICHE:            10,000 microfiche = 1 cubic foot

    STILL PICTURES:

         Negatives     2300 35 mm 6 exposures strips = 1 cubic foot
                       8640 2-by 2-inch mounted slides = 1 cubic foot
                       2184 4-by 5-inch film sheets = 1 cubic foot
                       5980 2 1/4-by 3 1/4-inch film sheets = 1 cubic foot

         Prints        2350 8-by 10-inch glossies or contact sheets  = 1 cubic foot
                       9400 4-by 5-inch glossies = 1 cubic foot

    MOTION PICTURES:      Six 35 mm reels (1000 feet) = 1 cubic feet
                              11  16 mm reels (1200 feet) = 1 cubic feet
                              15  16 mm reels (800 feet) = 1 cubic feet
                              32  16 mm reels (400 feet) = 1 cubic feet

    VIDEO RECORDINGS:     Ten 3/4 inch cassettes = 1 cubic foot
                              Three 2 inch reels = 1 cubic foot
                              Nine 1 inch reels = 1 cubic foot
                              43  1/2 inch reels = 1 cubic foot
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                                                            Records  Inventory
            identifies particular file cabinets,  drawers, etc. will simplify
            filling out the inventory  survey form while ensuring that all
            records are included in the document survey.

                  Perform Records Inventory Survey - Upon completion of
            these preparatory steps, inventory personnel will then begin the
            records survey, which directly examines the contents and the
            equipment  used  to hold  the  regional  file holdings.  The
            document survey consists of two phases:

                  •     Physical phase

                  •     Interview phase.

                  The  physical phase,   involves   both .physical  and
            chronological information about the records.  EPA staff and
            contractors  will examine  file holdings to  elicit quantifiable
            information concerning characteristics of documents managed
            by  the current system.    This examination  should  reveal
            individual records series, how they are used, and how they relate
            to each other.  Other types  of  information identified  in  the
            physical phase include the present volume of  records,  the
            percentage  of drafts,  duplicates,  confidential  business
            information, and the estimated growth of records.

                  The basic process for the physical phase consists of filling
            out one inventory survey form for each records series in the file
            holdings. This one-to-one relationship of survey form to records
            series, as well as the major records categories established earlier
            (i.e., administrative,  program), make it easier to sort  the forms
            into primary, secondary and tertiary classifications in the process
            of determining a file classification system  and retention schedule
            for  file holdings.  These topics will be discussed in subsequent
            sections of this chapter.

                  The physical phase  of the  records inventory should also
            include a  full equipment survey.  Information obtained in this
            survey should include the number, size, type, and features of
            storage cabinets (e.g., 36" lateral, 42" lateral, 2/3/4/5 drawer, what
            drawers have receding fronts, whether  the item has  a posting
            shelf).  In addition, any cabinets in disrepair should be identified.

                  The  interview phase  consists  of  interviewing  staff
            members  who  actually  use  and manage  the  information
            included in the records inventory.  Staff  members  should be


Model Regional Records Management Manual           (November 1991 draft)             55

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Records Management  Program  Components
            interviewed from all affected divisions and include Branch and
            Section  Chiefs, as well  as  clerical staff.  Interviews with staff
            members  from  each  division  assist  in  determining  the
            requirements  and preferences of the users in such areas as
            document access, storage, distribution, control, and processing.
            These interviews can also be used as an important tool to inform
            people of records management plans, needs, issues, and benefits.

                  Finally, a follow-up work group meeting where staff
            members can vocalize their opinions as well as obtain feedback
            on them provides additional information on the  characteristics
            of records and promotes coordination between the users.

                  Once the records  inventory  is  completed,  a records
            management program can be established that includes, but is not
            limited to,  the development of a file structure system, a records
            retention and disposition  schedule, a vital records  program,
            procedures on handling sensitive and confidential documents,
            and procedures on circulating and tracking records.
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                                                         Records  Classification
      2.  RECORDS CLASSIFICATION/FILE PLANS	

            The  following section discusses the design  of an effective
      classification system and its documentation in a files maintenance plan
      for file holdings  in each region based  upon the categories from  the
      records inventory.. The classification of records is the process  of
      determining the correct  file into which a record  should be placed. The
      file plan is the written outline of the arrangement assigned to a
      particular group of records and the corresponding codes. Several EPA
      examples of detailed file plans are included in  the attachments at  the
      end of this chapter.

            Regional general  management and program staff create and use
      the records. The records management staff will assist the regional
      managers  in  designing  an  effective  classification  system,  thus
      facilitating the integration process of new records  into  the records
      management program and increasing user accessibility.  The records
      management staff then  assumes responsibility for maintenance of  the
      file plan as the record collection matures.

            Objective

                  The objective  in developing a classification scheme and
            documenting it in  a file plan for an identified collection  of
            records  is  to  provide an  organizational  mechanism that
            facilitates future access to the information. Effective classification
            schemes do the following:

                  •     Provide categories for sorting and organizing
                        recorded information into simple structures which
                        are straightforward and clearly understood because
                        they  reflect the actual work being accomplished

                  •     Link  different collections of information in a
                        hierarchical relationship to provide a  logical
                        structure for performing document searches

                  •      Offer flexibility to allow for logical expansion
                        within the system for new categories.

                  In addition, the  classification system  must  be applied
            consistently in order to facilitate access  to related information
            across program, thus promoting media integration.


Model Regional Records Management  Manual           (November 1991 draft)              57

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Records  Management Program  Components
              Legal/Administrative  Requirements

                     The  list  below  identifies  a  variety  of  legal   and
              administrative requirements governing the  creation and use  of
              classification systems and file plans.
                            LEGAL AND ADMINISTRATIVE REQUIREMENTS^-
                        GOVERNING CLASSIFICATION SYSTEMS/FILE PLANS
                General Federal Guidelines at 44
                U.S.C. 3101-07. 41 CFR 101

                NARA Regulations at 36 CFR Part
                  1220

                CERCLA
                NCP
                Superfund Administrative Record
                  Guidance
                RCRA
                Freedom of Information Act
                EPA FOIA Manual
                NARA Guidance on Disposition of
                  Federal Records
                Superfund Administrative Record
                  Guidance
                Executive Order 11490, regarding
                  Specialized Records
                 IRM Policy Manual
                                 Government Agencies must create
                                 and maintain adequate and proper
                                 documentation of Government
                                 policies and activities
                                 Agency must provide a
                                 recordkeeping system that
                                 will facilitate public access
                                 to environmental program
                                 information
                                 An arrangement, or filing scheme,
                                 of a record series must be simply
                                 described in the file inventory

                                 Provides a model file structure
                                 for documenting the Superfund
                                 remedy selction process

                                 GSA must "provide instructions
                                 and advice on the ...
                                 arrangement,... of essential
                                 records for the operation of the
                                 Federal government"

                                 Agency must "apply, whenever
                                 practicable, appropriate
                                 standards and file structures to
                                 facilitate efficient filing, storage,
                                 and retrieval of records"
                     For a more detailed discussion of the citations listed here,
              the specific documents should be consulted.
58
(November 1991 draft)
Model Regional Records Management Manual

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                                                           Records  Classification
            Approaches

                   To meet  the  stated objective, the records officer works
            with regional staff to develop  program- or function-specific
            schemes to organize files and records for efficient storage and
            retrieval  based upon  categories from the records inventory
            survey.  Regions will likely develop a classification system for a
            group of records based upon the pattern of activities conducted
            within each program or  administrative  unit,  and  coded
            according to a  numeric, alphabetic or  other organizational
            system. This uniform system would  apply to paper, special (e.g.,
            maps, photos, etc.), and electronic records. To determine  an
            effective  classification system for  a given group or records,
            administrative and program managers, with the assistance of the
            records  management staff, should  take  into  account  the
            following issues, which are discussed in detail on  the following
            pages:

                   •      The pattern of records creation and usage

                   •      The applicability of existing file structures

                   •      The level of detail required to retrieve individual
                         records

                   •      The disposition requirements for a given record
                         series

                   •      The need for consistency to facilitate access to
                         related  information across programs.

                   The pattern of records creation and usage - Records may be
            used by  different  individuals/offices within  an organization for
            different  purposes. The  organizational file structure should
            reflect how records are created during the normal  operations of
            the Agency and how they will be used during their active life.

                   During the  records inventory, regional file holdings were
            classified as records,  non-records,  and a variety  of transitory
            materials.

                   •      Records of both general management and
                         programmatic information must be clearly
Model Regional Records Management Manual           (November 1991 draft)              59

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Records Management  Program  Components
                        identified as documentation of long-lasting value
                        to the Agency.

                  •     Non-records, including important reference and
                        convenience files, should be organized to facilitate
                        access and use by EPA staff in performing their
                        work.

                  •     Transitory files have an immediate value to the
                        work of the Agency and are generally identified for
                        management over a two year period of time.

            Within these larger categories,  many smaller groups of records
            were identified.  Ideally,  an organizational structure based upon
            these  categories from the records inventory  will  enable  the
            creators/users to physically consolidate the records, yet  easily
            retrieve individual documents,  or groups of related documents,
            as necessary.

                  File  classification systems  are  normally  developed  to
            organize and retrieve paper records, but all records, regardless of
            the media on which they are stored, should be classified  in the
            same  manner.  The files contained on magnetic  disks or other
            electronic storage media must be integrated  into the overall
            classification systems created for related records in the region.

                  Individual  files  must also be organized  and  stored
            according  to file  name conventions  that  reflect the  same
            creation,  use,  and retrieval  considerations of  the related
            information  sources  in  the   region.  An  identifying
            name/category must be assigned to a document as it is created
            and stored,  thus  necessitating an established convention  or
            structure for any retrieval.  Filenames should be standardized or
            patterned to provide a logical identifier for  each record. The
            labels on  the storage medium (magnetic disk, tape or optical
            disk)  should include the same major  and  minor names  or
            characters for identification as paper records in the same  series.
            To  maintain  consistency  in  the  classification  system,
            nonstandard records (e.g., maps, tapes, as well as sensitive or
            confidential/restricted information) are generally referenced in
            the program or  administrative  files and  physically  stored
            separately.

                  Because electronic records often do not appear to  belong to
            an established classification, a concerted effort should be made by


60              (November  1991 draft)            Model Regional Records Management Manual

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                                                          Records  Classification
            records officers, owners, and users to identify the uses and value
            of all  electronic records. In addition, electronic records needs
            have generated backup files, a unique category to classify.  Since
            more than one document may be stored on  a disk or tape, it is
            common  practice  to group documents;  this is  preferable  to
            random storage that relies entirely on an indexing data base to
            identify and locate a specific record.  This will be espically useful
            when it is time to apply disposition schedules to the files.

                   The applicability of existing file structures - Regions
            developing a new classification  system for any collection  of
            records would  benefit from examination  of  existing file
            structures. The records of administrative and program offices in
            a particular region are similar to those used by their counterparts
            at headquarters and in other regions.  Thus, the file structures
            utilized by these  offices may serve as  effective  models  for
            developing one's own file classification system. These existing
            file systems may be adopted by the regions in full or in part.  In
            addition, proven guidelines  that should be  followed when
            designing a coding scheme  for a classification system have been
            developed by NARA and the Association  of Records Managers
            and  Administrators (See attachment at the end of this section).

                  The level of detail required to retrieve - The needs of the
            users of each group of records will impact the detail of  the
            classification scheme and file plan at every level.  Developing a
            user profile (i.e., identifying who uses the records and how) is a
            useful  step  in  determining  the  logical  categories  and sub-
            categories  by which to structure  the records.  User interviews
            performed during the records  inventory may be appropriate to
            clarify issues based upon document access, storage, distribution,
            control, and processing,  and to answer questions such as:

                   •     What are the major functions of your
                        organization?

                   •     How is this group  of records used?

                   •     What is the logical name/category distinction of
                        this group of records?

                   •     Does this group of records constitute a general
                        category or a sub-category of something else?
Model Regional Records Management Manual           (November 1991 draft)              61

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Records Management Program Components
                  •     How does this group or records relate to others in
                        the division?

                  •     How does this group of records relate to similar
                        groups in other divisions?

                  •     How often are individual records in this group
                        accessed?

                  •     How long does this group of records remain in
                        active use?

                  •     Who else uses this group of records?

                  As  these questions indicate, the classification  system is
            influenced by the way the records were created. However, the
            objective  in  designing a classification system is to facilitate
            records access, and thus focuses primarily on the users' needs.

                  The internal arrangement of a collection of records may be
            described in several  ways,  including  combinations  of the
            following:

                  •     Alphabetically by subject

                  •     Chronologically by date of activity or report

                  •     Functionally by nature of activity or report

                  •     Numerically by sequence (i.e., voucher, permit, or
                        contract number).

                  It   is  recommended   that  regions   organize   their
            administrative files alphanumerically. Major subject areas are to
            be given an acronymic designation with minor subjects given a
            numeric  designation. Program  files should be organized
            alphabetically by project name or  numerically by ID number,
            subdivided by subject, and further subdivided by number code.
            Nonstandard files in the collection are to be referenced according
            to  the  structure of  the parent  file;  transitory  files and
            convenience files are to be kept chronologically  by  date of report
            or memo, or functionally by nature of subject matter.

                  Following is a list of subject headings used in classifying
            administrative records for filing:


62              (November 1991 draft)            Model Regional Records Management Manual

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                                                          Records  Classification
                 PRIMARY SUBJECT
                 ADMINISTRATIVE & MANAGEMENT
                  PROGRAMS
                 FINANCIAL MANAGEMENT
                 PERSONNEL
                 PUBLIC AWARENESS
           CLASSIFICATION CODE
                   AMP

                   FIM
                   PER
                   PUB
                 DETAILED FILING PLAN
                 AMP

                 AMP!
                 AMP2
                 AMP3
                 AMP4
                 AMP4-1
                 AMP4-2
                 AMPS
                 AMP6
                 AMP6-1
ADMINISTRATIVE & MANAGEMENT
PROGRAMS
POLICY AND PROCEDURE
REPORTS AND STATISTICS
FACILITIES MANAGEMENT
PROPERTY MANAGEMENT
  Office Equipment
  Word Processing Equipment
PRINTING SERVICES
INFORMATION MANAGEMENT
  Data Systems
                  If  the  natural  organization  of  a  group  of records
            necessitates more than one level of category or sub-category to
            identify a  specific document, the classification  system should
            reflect these major and minor breaks. Major (primary) categories
            are generally based on function.  Within  each major  break,
            records are arranged  into  minor (secondary  and  tertiary)
            categories.   A numbering/lettering system, such as that shown
            above, may be adopted in conjunction with the major categories.
            Minor breaks should identify their hierarchical positions within
            each major category.
                  Color coding  is  used frequently  with both  alpha and
            numeric file arrangements.  It may be added  to any classification
            system to  enhance recognition,  facilitate  visual reference, and
            avoid misfiles.  Sometimes  it is  actually used  in  place of a
Model Regional Records Management Manual
         (November 1991 draft)
63

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Records Management Program Components
            primary classification that represents a name, number, or group
            of words.  Color coding is commonly used with a classification
            system to identify enforcement sensitive or confidential business
            information that requires special handling.

                  Disposition schedules for a given record series - Schedules
            for retaining, disposing of,  or  archiving Agency records are
            mandated by federal law and defined in EPA records disposition
            schedules (See discussion on Records Disposition).  It is a logical
            practice to establish specific categories and sub-categories in the
            Region's  classification system  that  parallel  the categories
            prescribed  in  retention   and  disposition  schedules. Thus,
            documents will be  grouped  so that those with some retention
            requirements  are  grouped together.  Further,  this  parallel
            classification system facilitates efficient and timely transfer to the
            Federal Records Centers,  scheduled destruction, or in regional
            storage.

                  The need for consistency to facilitate access to related
            information   across  programs -  Within the objective of
            facilitating access  to records through the development of an
            appropriate classification  system, there is an implied need for
            establishing consistency at-a basic level for similar collections of
            records across programs  within a region,  as well as across
            regions.  Regions should  encourage consistency across records
            collections for any classification system adopted, so that a set of
            standards is applied that allows program and  non-program users
            to recognize and access records relevant  to their  mission.  For
            example,  the Superfund site files in  all Regions  are generally
            structured by states, then alphabetically  by site name and/or
            numerically by the Site/Spill (S/S) ID  number, and further
            broken down by phase of response. The  overall consistency of
            this classification system  for Superfund records promotes easy
            identification  of  records associated  with  that  site when
            communicating outside the  program or  with another Region,
            thus furthering media information integration.

                  In  keeping  with  the need for  consistency,  distinct
            collections  of  records in the  region could also  employ  a
            consistent internal numbering/lettering system across programs.
            For example, Section B.I of any facility/site/etc. file in any media
            program  could be designated  as the classification code for
            Correspondence.  This approach recognizes that although the
            overall  classification scheme for a group of records must be
            tailored to its content, there is a high degree of regulatory and


64              (November 1991 draft)           Model Regional Records Management Manual

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                                                          Records Classification
            facility/site/etc. overlap among the environmental program
            records in the region.

                  A standard  Regional file  classification system  that  is
            flexible enough to be applied in all divisions greatly simplifies
            cross-program and cross-regional coordination needs.  Sample
            file  structures used in  regional  Superfund  and other media
            programs are included in the attachments to this section.

             References

                  The following documents  contain  information on file
            plans and filing equipment that may be useful in  developing
            regional filing schemes.  They are  available from NARA and
            GSA.
                        Evaluating Files Maintenance
                        Regional File Manual EPA
                        Case Filing
                        Files Equipment and Supplies
                        Files Operations
                        File Stations
                        Subject Filing
Model Regional Records Management Manual           (November 1991 draft)              65

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Records  Management  Program  Components
66              (November 1991 draft)            Model Regional Records Management Manual

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                                                Records Classification
                        ATTACHMENTS
               •    Region III Regional Administrator File
                    Sturcture

               •    Toxic Substances Program Administrative
                    File Plan

               •    Classification Coding Form for Region VII
                    Site Records

               •    Files Maintenance Plan for Administrative
                    Records
Model Regional Records Management Manual         (November 1991 draft)           67

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Records  Management  Program Components
68              (November 1991 draft)            Model Regional Records Management Manual

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        Region III  Regional  Administrator  File
                               Structure
                            CERCLA FILE STRUCTURE
                    rar
           Background  V
           Notification/Site Discovery V
           PA/SI Reports  V
           HRS Reports
           Correspondence V
           Disposition/NPL Ranking

           dial  Enforcement".  Planning  V
           PRP Search  Information
           -  Reports
           -  General Correspondence
           -  Correspondence by PRP
           PRP-Generated  Reports  and Data V
           Orders V
           -  Negotiations V
           -  Draft  Orders and Comments
           -  Signed Order V
           -  Compliance Monitoring

              l  Response Planning  V
           Work Plan V
           RI/FS Reports  V
           Health Risk/Endangerment Assessment V
           Correspondence V
           Work Assignments
           ROD/EDO V

              l  Enf nregmenf  Imr> lf»mpnrar ion V
           Consent Decrees V
           -  Negotiations V
           -  Draft  Consent Decrees and Comments
           -  Final  Consent Decree V
           Settlements V
           -  Implementation Notice Letters  and Correspondence
           -  Proposals V
           -  Signed Settlement V
      NOTES;  All site files  will be filed by state and by site name.  Documents
      within file sections will be filed in reverse chronological order.   File
      sections containing Administrative Record documents according to the
      current guidance are denoted by a check mark (V).  Raw data and chain of
      custody seals  will be stored in the Central Regional Laboratory in
      Annapolis,  Maryland; these materials will be identified as appropriate in
      each Administrative Record index.  Guidance documents and technical
      sources must be available somewhere in the region and identified in  the
      Administrative Record index.
Model Regional Records Management Manual           (November 1991 draft)              69

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Records Management Program Components
                                      CERCLA FILE STRUCTURE  (cont.)

                      Remedial Tirrplemen^ar i np
                        •  Remedial Design
                        •  Remedial Action
                        •  Deletion
                        •  Operation and Maintenance
                        •  Correspondence
                        •  Work Assignments

                      Emergency Removal Response Prnjegfs V
                        •  Technical Documents V
                        •  Operational Documents V
                        •  Financial Documents V
                        •  On-Scene Coordinator's Report V
                        •  Photo Documentation

                      Removal  Enfnrcemenr  Response V
                        •  PRP Search Information
                          - Reports
                          - General Correspondence
                          - Correspondence
                        •  PRP-Generated Reports and Data V
                        •  Orders V
                          - Negotiations  V
                          - Draft  Orders  and Comments
                          - Signed Order  V
                          - Work Plans  V
                          - Feasibility Studies V
                          - Compliance  Monitoring

                      Twaqrery

                              iona I Corresondence V
                     ("nmrrmnir
                          Community Relations Plan V
                          Fact Sheets, Press Releases, Public Notices  V
                          Meeting Summaries, Trip Reports V
                          Newspaper Articles
                          Interagency Meeting Notes, Correspondence V
                          FOIA Requests/Responses
 70              (November 1991 draft)           Model Regional Records Management Manual

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                                                          Records Classification
                                 CERCLA FILE STRUCTURE (cont.)

                    ^L  Recover   Financial  Parkae
                     Case Resolution Document
                     Cost Recovery Documentation Checklist
                     Software Package for Unique Reports  (SPURS)
                     General Correspondence
                     Cost Summary Report
                     Payroll (HQ and Region)
                     Agency Indirect Costs
                     Travel (HQ and Region)
                     Contracts by Contractor
                     Interagency Agreements (lAGs)  by Agency
                     State Cooperative Agreement or State Contract
                     National Enforcement Investigation Center
                     Environmental Photographic Interpretation Center
                     Miscellaneous Procurement Expenses

                     3 Arr ions
                     Cost Recovery
                     - Technical  Support Document
                     - Referral/Case Development Plan
                     - Correspondence  - Internal  (DOJ,  AUSA,  HQ)
                     - Correspondence  - Outside Counsel
                     - Pleadings
                     - Motions
                     - Administrative  Record
                     - Discovery  Requests  Produced by  EPA
                     - Discovery  Requests  Produced by  Defendants
                     - Technical  Evidence
                     - PRP Evidence
                     - Witnesses
                     - Legal Research
                     - Opinions
                     - Case Resolutions

                     Injunctive Relief Actions (Section 106)
                     - Endangerment Determinations and Supporting Documents
                     - Remedy
                     - Compliance Monitoring
                     - Technical  Support Document
                     - Referral/Case Development Plan
                     - Correspondence  - Internal  (DOJ,  AUSA,  HQ)
                     - Correspondence  - Outside Counsel
                     - Pleadings
                     - Motions
                     - Administrative  Record
                     - Discovery  Requests  Produced by  EPA
                     - Discovery  Requests  Produced by  Defendants
                     - Technical  Evidence
                     - PRP Evidence
                     - Witnesses
                     - Legal Research
                     - Opinions
                     - Case Resolutions
Model Regional Records Management Manual           (November 1991 draft)              71

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Records Management  Program Components
                (November 1991  draft)           Model Regional Records Management Manual

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                                                        Records Classification
                   Toxic  Substances  Program
                    Administrative  File  Plan
                              FILES MAINTENANCE PLANS
                        AIR AND HAZARDOUS MATERIALS DIVISION
                              TOXIC SUBSTANCES PROGRAM
                              ADMINISTRATIVE RECORDS


         ADS        ADMINISTRATIVE SERVICES
         ADS  1      POLICY AND PROCEDURE
         ADS  2      REPORTS AND STATISTICS
         ADS  4      PROPERTY MANAGEMENT

         BUA        BUDGET ADMINISTRATION
         BUA  2      REPORTS AND STATISTICS
         BUA  4      BUDGET PREPARATION

         EXR        EXTERNAL RELATIONS
         EXR  3      CONGRESSIONAL RELATIONS
         EXR  4      INTERAGENCY RELATIONS AND AGREEMENTS
         EXR  5      STATE AND MUNICIPAL RELATIONS
         EXR  6      ASSOCIATIONS COMMITTEES  AND BOARDS   (Establish  files  con-
                              taining material relating to  advisory groups,
                              task forces, professional groups,  conferences,
                              boards, committees,  and  associations.  Establish
                              a case file for each group,  arranged  alpha-
                              betically by name of group.)

         FIM        FINANCIAL MANAGEMENT
         FIM  5      TRANSPORTATION  (Establish case files  for employee travel,
                              arranged alphabetically  by  name of employee.)

         LEL        LEGAL AND LEGISLATIVE
         LEL  3      LEGISLATION
         LEL  3-1      Federal  (Establish case files  for  proposed and final
                              environmental and toxic  substances legislation.)
         LEL  3-2      State  (Establish case files for state toxic  substances
                              legislation.)
         LEL  3-3      Local and Regional  (Establish  case files  for local.and
                              regional toxic substances legislation.)
         LEL  5      RULES AND REGULATIONS  (Establish  case  files for all pro-
                              posed and final standards,  regulations, and
                              guidelines promulgated  under  the Toxic Substances
                              Control Act.)

         MAP        MANAGEMENT PROGRAMS

         ORF        ORGANIZATION AND FUNCTION
         ORF  3      BASIC ORGANIZATIO-N  (Include organizational  charts,
                              functional statements,  and  related material.)
Model Regional Records Management Manual          (November 1991 draft)             73

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Records Management  Program  Components
     FILES MAINTENANCE  PLAN
     AIR AND HAZARDOUS  MATERIALS  DIVISION
     TOXIC SUBSTANCES PROGRAM    (CONT'D)
     PER        PERSONNEL
     PER 6      EMPLOYMENT   (Applicants,  appointments,  and recruitment
                          files.)
     PER 7      PERSONNEL  RECORDS   (Establish an individual case file
                          for  each  employer.)
     PER 12     PERSONNEL  ACTIONS AND  REQUESTS

     PUA        PUBLIC  AFFAIRS
     PUA 2      PRESS RELEASES
     PUA 3      NEWS CUPPINGS
     PUA 4      SPEECHES
                             PROGRAM RECORDS


     EMR        EMERGENCY  RESPONSE
     EMR  5      EMERGENCY  RESPONSE - HAZARDOUS MATERIALS
     EMR  5-1      Investigations   (Establish case file for each Incident.)
     EMR  10     EMERGENCY  PLANNING

     ENF        ENFORCEMENT
     ENF  6      TOXIC  SUBSTANCES  ENFORCEMENT  (Establish case files £«*-
                          each case under investigation, arranged alpha-
                          betically by name of cheaical company.)

     CEO        GEOGRAPHICAL SUMMARY DATA  (Use this category to file
                          material of a general nature related to assign-
                          ments of responsibility for specific geographic
                          areas,  such as states, localities, etc.)
     GEO  3      GEOGRAPHICAL ASSIGNMENTS  (Establish a case file for each
                          area assigned, arranged alphabetically by area
                          name.)

     GRA        GRANTS  ADMINISTRATION
     GRA  1      POLICY  AND PROCEDURE
     GRA  A      DEMONSTRATION GRANTS  (Establish case files for any grants
                          made under the Toxic Substances Control Act.)

     LAB        LABORATORY SUPPORT
     LAB  9      IDENTIFICATION METHODS  (Establish case files for testing
                          and analytical methods and procedures related
                          to toxic chemicals.)

     MON        MONITORING
     MON  A      ENVIRONMENTAL MONITORING
     MON  4-12     Toxic Substances  (Establish case files for the collec-
                          tion of monitoring data relating to toxic sub-
                          stances . )
 74              (November 1991  draft)           Model Regional Records Management Manual

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                                                          Records  Classification
           FILES MAINTENANCE  PLAN
           AIR AND HAZARDOUS  MATERIALS DIVISION
           TOXIC SUBSTANCES PROGRAM   (CONT'D)
           PLA       PLANNING
           PLA 3     WORK  PLANS
           PLA 6     SPECIAL  STUDIES  (Establish case files for each special
                                study related to toxic substances control.)
           PLA 8     PROGRAM  PLANNING

           RDE       RESEARCH  AND DEVELOPMENT
           RDE 3     RESEARCH  PROJECTS REVIEW   (Establish case files for  all
                                projects reviewed.)
           RDE 5     ENVIRONMENTAL RESEARCH LABORATORIES   (Establish files  for
                                general correspondence with the laboratories
                                and field stations.)

           TSC       TOXIC SUBSTANCES CONTROL
           TSC 1     POLICY AND  PROCEDURE
           TSC 2     REPORTS  AND STATISTICS  (Use this category to  file pro-
                                gram activity reports and other statistical
                                data. )
           TSC 3     CHEMICALS REFERENCE   (Establish case  files containing
                                reference materials on all  toxic chemicals  that
                                are or may be hazardous to human health or  the
                                environment, arranged alphabetically by name  of
                                chemical substance.)
           TSC A     TOXIC SUBSTANCES INVENTORY   (Establish case files contain-
                                ing Information  submitted by the chemical  in-
                                dustry on the names, production, voluae, and
                                manufacturing sites of all  toxic chemicals  in
                                commerce . )
           TSC 5     NEW CHEMICALS EVALUATION   (Establish  case filef on regional
                                evaluations of new chemicals coming  on  the market
                                that may be harmful to human health  or  the en-
                                vironment .

           TSU       TECHNICAL SUPPORT
           TSU 5     ENVIRONMENT IMPACT STATEMENTS   (Establish case files of  en-
                                vironmental impact statement reviewed by  the
                                toxic substances staff.)
Model Regional Records Management Manual           (November 1991 draft)             75

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Records  Management Program  Components
76              (November 1991 draft)            Model Regional Records Management Manual

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                                                            Records Classification
                   Classification  Coding  Form
                   for  Region  VII Site Records
             Records Classification Coding Form for  Region VTI Site Records
                               {See Reverse Side for Instructions)
          1.   Site Name:
          2.   CERCUS ID #:
          3.   Major/Minor Break for this Record:
          4.   Operable Unit(s):     No        Yes:

          5.  Sensitivity Rating for this Record:	
          6.  Should this Record be Included in the Administrative Record?  No    Yes

          7.  Should this Record be Included in Cost Recovery actions?     No    Yes

          8.  Name of Person Submitting Record:	


          9.  Telephone Number	    10. Date: 	

          11. Mail Code: 	

          12. Number of Records Covered by this Form:
         Notes (Superfund Records Center Use Only):
     EPA KCJJOO
Model Regional Records Management Manual           (November 1991 draft)               77

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Records Management  Program Components
78              (November 1991 draft)            Model Regional Records Management Manual

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                                                            Records Classification
                      Files  Maintenance   Plan
                   for Administrative  Records
         Records Management                                             2160
                                                                      7/13/84
                     SUBJECT CLASSIFICATION OF ADMINISTRATIVE RECORDS

         The following is a list of subject headings used in classifying administrative records for
         filing.  These records include "housekeeping" or facilitative records that do not relate
         directly to the programs or mission of your office.
        PRIMARY SUBJECT HEADING     '                     CLASSIFICATION CODE

        Administrative and Management Programs                     AMP

        Budget Administration                                     BUA

        Financial Management                                     FIM

        Personnel  '                                              PER

        Program Planning                                         PRP

        Public Awareness                                         PUB
                                 Figure 7-4 (Part -1  of 3)
                    Files Classification System for Administrative Records
Model Regional Records Management Manual            (November 1991 draft)               79

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 Records  Management  Program  Components
             Files Maintenance Plan for Administrative Records (cont'd)

    Records Management                                                 2160
                                                                         7/13/84
                  FILES CLASSIFICATION SYSTEM FOR ADMINISTRATIVE RECORDS

                                      Administrative Records

    AMP          ADMINISTRATIVE AND MANAGEMENT PROGRAMS
    AMP 1         POUCY AND PROCEDURE
    AMP 2         REPORTS AND STATISTICS
    AMP 3         FACILITIES MANAGEMENT (Use this classification to file materials pertaining to
                        space assignment and facilities management, maintenance, and
                        protection).
    AMP 4         PROPERTY MANAGEMENT (Use this classification to file materials pertaining to
                        the management, maintenance, and protection of Federally owned
                        personal  property).
    AMP 4-1         Office Equipment -  Service and Maintenance
    AMP 4-2         Word Processing Equipment
    AMP 5         PRINTING SERVICES
    AMP 5-1         Printing Requisitions
    AMP 6         INFORMATION MANAGEMENT
    AMP 6-1         Data Systems (Use this classification to file materials pertaining to the
                        development  of data systems, including ADP systems, and other
                        automated information storage and retrieval  systems).
    AMP 6-2         Documentation Management
    AMP 6-2-1        File Maintenance  Plan
    AMP 6-2-2       Records Disposal and Retirement
    AMP 7         MAIL AND MESSENGER SERVICES
    AMP 8         TELECOMMUNICATIONS (Use this classification to file materials
                        pertaining to the use of telephone and other office
                        communications devices).

    BUA          BUDGET ADMINISTRATION
    BUA 1         POLICY AND PROCEDURES
    BUA 2         REPORTS AND STATISTICS
    BUA 3         APPROPRIATIONS AND FUNDING
    BUA 4         BUDGET PREPARATION
    BUA 4-1         Personnel
    BUA 4-2         Support Services
    BUA 4-3         Travel
    BUA 4-4         Budget Department
    BUA 4-5         Workload Analysis

    FIM           FINANCIAL MANAGEMENT
    FIM 1         POUCY AND PROCEDURES
    FIM 2         REPORTS AND STATISTICS
    FIM 3         PAYROLL

                                  Figure 7-4 (Part 2 of 3)
                     Files Classification System for Administration Records

80               (November 1991  draft)             Model Regional  Records Management Manual

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                                                                  Records  Classification
               Files Maintenance Plan for Administrative Records (cont'd)

            FIM 4         EMPLOYEE TRANSPORTATION
            FIM 4-1         Employee Travel (Includes material pertaining to employee-per diem,
                                travel arrangements, and related materals. Establish a case file
                                for each employee who performs official travel).
            FIM 5         PROCUREMENT
            FIM 5-1         Purchase Requests

            PER          PFRsnNM=l
            PER1         POUCY AND PROCEDURE
            PER 2         REPORTS AND STATISTICS
            PER 3         ATTENDANCE
            PER 4         EMPLOYEE PERFORMANCE AND UTILIZATION
            PER 4-1         Training and Career Development
            PER 4-2         Performance  Evaluation
            PER 4-3       Employee Recognition and Incentives
            PER 5         EMPLOYMENT (Applicants, Appointments, Recruitment)
            PER 6         GENERALPERSONNEL
            PER 6-1         Inspections, Surveys, and Audits
            PER 6-2         Personnel Records (Estiblish and individual case file for
                               each employee.  Include all personnel records relating
                               to the individual).
            PER 7         HEALTH AND INSURANCE
            PER'8         EMPLOYEE RELATIONS
            PER 8-1         Employee Responsibilities and Conduct
            PER 9         POSITION CLASSIFICATION, JOB DESCRIPTIONS. PAY ALLOWANCES
            PER 10        SEPARATION
            PER 11        PERSONNEL ACTIONS AND REQUESTS
            PER 12        EQUAL EMPLOYMENT OPPORTUNITY (Use this Classification for
                               all material pertaining to EEO, Civil  Rights, and  Minority
                               Employment).
           PER 13        RESUMES OF EMPLOYEES AND POTENTIAL CANDIDATES

           PRP           PROGRAM PLANNING
           PRP1         POUCY AND PROCEDURES
           PRP 2         REPORTS AND STATISTICS
           PRP 3         ORGANIZATON PLANNING
           PRP 3-1         Functional Statements
           PRP 3-2         Organization  Charts
           PRP 4         DELEGATION OF AUTHORITY
           PRP 5         BREF1NGS

           PUB           PUBLIC AWARENESS
           PUB 1         PRESS RELEASES
           PUB 1-1        Public Opinion
           PUB 2         NEWS CLIPPINGS
           PUB 3         SPEECHES
           PUB 4         NEWSLETTERS
           PUB 5         AUDIO- VISUAL MATERIALS
           PUB 6         FREEDOM OF INFORMATION REQUESTS

                          Figure 7-4 (part 3 of 3)
	Files Classfication Sysem for Administrtaion	

Model Regional Records Management  Manual            (November 1991 draft)               81

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                                                          Document  Control
      3.  DOCUMENT CONTROL
            EPA's  regional offices  handle  an  increasing  volume of
      documents each year.  In  combination with an effective organizational
      structure, a comprehensive document control procedure is necessary to
      provide quick and efficient access to Agency files.  Ideally, a system
      applicable to each region, providing a consistent approach throughout
      the Agency, addresses two records management functions: information
      retrieval assistance and file/record maintenance.

            Many document control  procedures can  be designed  and
      implemented by individual staff officers.  A records center becomes an
      attractive management resource, however, as the volume of records in
      storage and circulation increases.

            Structured  document  control  measures  are  an  integral
      component of effective records management, a process that begins with
      file organization  and then is supported and maintained  by a file
      tracking system.  The following section describes  the procedures to be
      considered in. designing a  document control system.

            Objective

                 The  objectives  of  implementing  document control
            procedures within  the Agency's records management program
            are to facilitate access to and availability of information and to
            maintain control over  the files  as  they are used and updated.
            Additionally,  the  document  control procedures  must  be
            understood by users and applied uniformly.

            Legal/Administrative Requirements

                 Major legal/administrative requirements for information
            retrieval assistance  and  file/record  maintenance are highlighted
            on the following page.
Model Regional Records Management Manual          (November 1991 draft)             83

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Records  Management Program  Components
                         LEGAb AND ADMINISTRATIVE REQUIREMENTS-
                      FOR RECORDS CENTER CIRCULATION PROCEDURES
                General Federal Guidelines at 44
                U.S.C. 3103-07. 41 CFR 101 NARA
                Regulations at 36 CFR Part 1220
                CERCLA NCP
                Superfund Administrative Record
                Guidance RCRA HSWA
                Freedom of Information Act
                EPA FOIA Manual

                IRM Policy Manual
                             Government Agencies must create
                             and maintain adequate and proper
                             documentation of Government policies
                             and activities

                             Agency must provide a recordkeeping
                             system that will facilitate public
                             access to environmental program
                             information
                             Agency must 'apply, whenever
                             practicable, appropriate standards and
                             file structures to facilitate efficient
                             filing, storage, and retrieval of records"
             Approach

                   In order  to  accomplish the objectives  stated  above  and
             fulfill the legal and administrative requirements, a document
             control procedure must be designed that will provide users with
             easy access to the files and yet allow  the records management
             staff to maintain  control of  the  documents. As with records
             classification/file plans,  regional  records officers should work
             with program and administrative  staff  to develop the document
             control  procedures.  Throughout  this   development,  the
             following components  of a document control system should be
             taken into account:

                   •     File/document retrieval

                   •     File/document return

                   •     File update/maintenance

                   •     Creation of new files

                   •     Special document handling procedures

                   •     Closed or  infrequently used files.

             Each of the above is discussed in more detail below.
84
(November 1991 draft)
Model Regional Records Management Manual

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                                                            Document  Control
                        File/document  retrieval  - The most important
                  function of a records management program is the daily
                  exchange of  files and documents through  a circulation
                  procedure similar to a library check-out system. Access to
                  files should  be limited  to  EPA personnel who have
                  borrowing privileges in a specific program  area. EPA staff
                  may check  out files for contractor use or for  others
                  wishing to view the files; however, the individual EPA
                  staff member  retains  ultimate  responsibility for  the
                  safekeeping  of the  documents.-  To  facilitate access,  a
                  viewing area  should be provided for staff and members of
                  the public who wish to review Agency documents.

                        Ideally, a records retrieval  system should combine
                  both computerized tracking of files and/or documents and
                  hard copy circulation forms.

                        Maintaining  regional  records information in  a
                  computer database allows for  efficient and  timely access to
                  a broad range of document control data. Some examples
                  of the types of information readily available from  such a
                  system include:

                        •     Name, address, current status  of any
                              facility/site

                        •     EPA identification number

                        •     Listing of authorized  borrowers

                        •     Current file location

                        •     Transaction dates

                        •     Cross-referencing of related  material stored
                              in other areas.

                  In any case,  a computerized tracking system should be
                  developed to correspond to the records  classification/file
                  plans.

                       In addition to providing immediate facility or site-
                  specific information,  the  computer database maintained
                  in each region generates a wide range of reports detailing
                  such information as the circulation status  of a particular


Model Regional Records Management Manual           (November  1991  draft)              85

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Records Management Program Components
                  group of files or the entire contents of the records center's
                  current  inventory. Once established, configuration of the
                  system for a local area  network (LAN)  will provide easy
                  access for users of the files/documents.  It-is important;
                  however, that  only records managment staff have the
                  ability to make changes to the system and that users are
                  only able to read the information contained in the records
                  classification system.

                        The  use of  circulation forms, corresponding to
                  the records classification  system,  provides  back-up
                  documentation of records center transactions to reinforce
                  the information management capabilities of the computer
                  system.   Simultaneous implementation  of both strategies
                  effectively  reduces the  time required to locate  files  and
                 • provide needed information.  Consequently, an increase
                  in overall access to file information results. This increased
                  access   facilitates  related  Agency  activities,  such  as
                  compilation of  administrative  record files,  litigation
                  preparations, cost recovery efforts, contractor  oversight,
                  and coordination of state and local government activities.

                        File/document  return - Return of files/documents
                  to the records center  should correspond to  the check-out
                  system.   For instance, if a the circulation form  is used, it
                  should accompany the returned files for easy update of the
                  system. File/document users  should be encouraged to
                  return files/documents to the records center promptly and
                  in original  condition.  Upon  return, the computerized
                  tracking systems should be updated as quickly as possible
                  to allow other file users the opportunity  to access the
                  files/documents.

                        The computerized tracking system also can be used
                  to track those files that have been out of the records center
                  for an extended period of time.  Reports can be generated
                  and sent   to  file  users  asking  for  the  return  of
                  files/documents.  These  reporting  capabilities of  a
                  computerized tracking, system enhance the circulation
                  system's overall file tracking  function and facilitate such
                  tasks as the determination of deadlines for file disposition
                  or for return of overdue files.  Additionally, computerized
                  tracking of files reduces the possibility of damage or loss
                  and contributes to an overall awareness of responsibility
                  on the part of file users.


86              (November 1991 draft)           Model Regional Records Management Manual

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                                                            Document  Control
                        File  update/maintenance  -  Records  center
                  personnel, in  addition  to providing information  access,
                  contribute to control of Agency records through routine
                  file updates and maintenance.  Generally, files continually
                  increase in volume with the introduction of new  phases
                  of work and the accompanying documentation associated
                  with Agency activities at a particular facility or site. Using
                  the organizational file structure created for each program,
                  records  center personnel not only ensure that files  in
                  circulation are returned intact and in good condition, but
                  also regularly  update active  files  by  inserting  new
                  information as it is received.

                        Procedures for updating files  may  include the
                  following:

                        •     Submitting file  circulation form with
                              material to  be added to the file

                        •     Organizing files to correspond to record
                              classification system

                        •     Updating the computerized tracking system

                        •     Updating files in records center with new
                              information

                        •     Creating a "hold/update" file for files that are
                              currently checked out.

                        Any  updating or maintenance procedures should
                  be adapted to the type  of files being updated,  i.e. paper
                  versus electronic.

                        Creation of new files -  Documents for newly-
                  identified facilities or sites should be entered into the
                  records center system as soon as possible.  Procedures for
                  creation of new files should follow  those procedures
                  outlined for updating  files, i.e. updating  the  tracking
                  system,  organizing  the  files  according   to  the  file
                  classification system, and  encouraging  submission  of
                  documents in a timely manner.

                        Special  document handling procedures -  Another
                  vital function of a records center circulation system is  to


Model Regional Records Management Manual           (November 1991 draft)              87

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Records Management Program  Components
                  establish special handling procedures for documents/files
                  that do not fit into the general classification system.  These
                  include the following:

                         •     Confidential business information (CBI)

                         •     Oversized documents

                         •     Potentially FOIA exempt documents (PFE)

                         •     Electronic formats.

                         It may be necessary to have increased control over
                  some of the above mentioned Agency records at both  the
                  file and document levels.  Establishing  separate locations
                  in the records center, tracking these documents separately
                  on the computerized tracking system,  and/or stamping
                  these  files  or documents  to  indicate  CBI  or PFE
                  information  should enhance the management of these
                  documents/files.  In any  case, the circulation practices
                  should promote file security and protect the integrity of
                  these special  Agency documents.

                         Closed or infrequently used files -  As the number
                  of documents and files in the records center increases,  the
                  establishment of procedures for  handling  closed   or
                  infrequently used files becomes necessary.  Microfilm and
                  off-site archiving are two records  storage options designed
                  to utilize  Agency space more effectively.  While access to
                  files stored off-premises or retained  on microfilm  is less
                  immediate than in the traditional records center scenario,
                  judicious  application of such methods  to less  active files
                  can contribute to improved  accessibility of all  files.
                  Finally, systematic reduction of file materials through  the
                  application of file disposition guidelines also allows  for
                  greater utilization of existing space and  for easier access to
                  more current information.

                         No  matter  what  practices  or procedures   are
                  established for circulation of files,  it  is important  that
                  these are  consistent across programs.  Additionally, roles
                  and responsibilities of file users versus records  center staff
                  should also  be clearly  delineated. Finally, electronic
                  recordkeeping practices should  be incorporated into as
                  many aspects of a circulation system as possible.


88              (November 1991 draft)           Model  Regional Records Management Manual

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                                                Document Control
                       ATTACHMENTS
                   Region III CERCLA File Circulation and
                   Update Form
                                    Form for Superfund Site
                   Files

                   Region VII Certification Form for Authorized
                   Access
Model Regional Records Management Manual         (November 1991 draft)           89

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Records  Management  Program Components
90              (November 1991 draft)           Model Regional Records Management Manual

-------
                                                                            Document  Control
              Region  III   CERCLA  File   Circulation
                               and   Update  Form
Site Nam.-
dfafj. nr fl
REMEDIAL ENFORCEMENT         ?,  ^T*	T     "<>*>"•            	12f
PLANNING (red)                  Signed Order	70     Admtnt«rative Record	12g
                                WorkPlan            	7h     Discovery Req - EPA	-J2h
  PRP Search Reporta	2*.   Feaatolty SUdy	71     Diecovery Req - Defend	131
  PRP General Corr  	,_	3b    Compliance Men	7|     Technical Evidence	12!
  Con-byPRP	2c                              	    PRP Evidence	-|2k

  ££?££££	£•  '"AOEiiy (8ow«,«d)                  rrr*—.       =—««
  Order* - Negotiation*	__2»:                                      Legal Reaearch	i_12m
  OraftOrdar	21    Enflre File            	_1. r" «   Opinion*           HZ I~Zl2n
  Signed Order	20:                                 —'   Caae Reeotudon*     	   ~ ilo
  Compliance Mon	2h   CONGRESSIONAL
REMEDIAL RESPONSE            CORRESPONDENCE (*llv*r)
PLANNING (red)                  _   _                  _.„.  „_.
          l   '                  ErrtreFile            	L»^"   WJUNCT1VE REUEF
  WorkPtari	jft                                -•     ACTIONS FU
  2"flfJ!*SV	2b-  COMMUNITY  INVOLVEMENT            Enoawgermant Oetarm
  Health RI*k>Endangr	3ct  (y,,,ow,                              Remedy
  Correapondenc*   	•	3d!  (y"low'                              CompianceMon
  Work Aaalgnmarrt*  	     3a^   Communcy Ratal Ran   	 """Iff*    Tech Support Doc
  ROD /EDO	3»    Fad Sheet*	1Qt>    Referral
REMEDIAL ENFORCEMENT         Meeang Summarte*	10c    Corr-Internal
IMPLEMENTATION  (red)           ^'Z*??."*^	10d    Corr-OutakJe
                                Meeting rJotee. Corr     	 .._   10«v   Pleading*
  Cement Oecr-Negot	4a    FOU               	10f    Modona
  Draft Consent Decree	4b                                       AdmWatratfve Record
  Final Consent Decree	4e.                                      Dtooovery Req - EPA
  ^•"""|?*L  .	*d   COST RECOVERY  FINANCIAL           OUcovery Req - Defend
  Setflement Proposal*	4*'  PACKAGE  (ar..n)                     Technical Evidence
  Signed Setflement	4f   »'**-'>-*^e  igreen,                     pqp Evidence

REMEDIAL                  '*"   ^>^^°"I°°C	""•""   ™*~~
IMPLEMENTATION  (r»d)           nf"*'0^*"'	11bf<   Legal Reeeerch
                      	       SPUR               	     Ha..   Oplnione
  Remedial Dealgn   	2~Zf««   General Corr          	     11d •   Caae Reeotudon*
                                Coat Summary Report
                                Payroll (HO. A Region)         .. •  • 111 ~  eunnr me
  Operaflon4M^	^_a<*i   Agency tnoVeoTcoet.   ——--, ,^  BMTOW FILE
  Correapondenoe            «*«   Travel (HO»Regoi)
  Work AMignmant*	_jf-   Contraca by Contractor
                                  IAG« by Agency	11|
                                  St«tt»> Coop AQrmntt     	 ••»•— 11 kv
                                                                    Today** Date
                                                                   Date Returned:
                                                                      Entered  By:
 EMERGENCY REMOVAL

  (°«n«->               	     EPC
   Technical Ooca	B*s    Mlac Expen*e*

   F^anSarOoca00*	r~"«c^                                      Sh*xl«^ area* for File Staff uae only
   OSC Report      HH     Btt-
   Photo Doe	g*~



Model Regional Records Management Manual              (November 1991 draft)                  91

-------
Records Management  Program Components
92              (November 1991 draft)            Model Regional Records Management Manual

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                                                Document  Control
                Region VII Signout  Form
                 for Superfund  Site Files

Signout Form for Superfund Site Files
Instructions:
• Authorized borrowers must complete all appropriate sections of me form.
• Questions concerning the borrowing of site files may be directed to me Superfund Records Center Manager.
1. Site Name:
2. CERCLISID#Ofknown):
3. Operable Unit

4. State (circle one): LA KS MO NE
5. Material to be
Borrowed
Major/Minor Break
a
b
c
d
For Superfund Records Center Staff Use Only
Bar Code
Number

a
b
c
d
Special Date Checked Date Returned
Authorization Out by Borrower by Borrower
Signature
-
a a a
b b b
c c c
d d d
6. Name of Authorized Borrower
7. Division/Section:

8. Mail Code:
9. Telephone Number



Model Regional Records Management Manual
(November 1991 draft)
93

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Records  Management  Program Components
94              (November 1991 draft)           Model Regional Records Management Manual

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                                                                  Document  Control
                 Region  VII  Certification  Form
                        for  Authorized  Access
    MEMORANDUM
    DATE:
    FROM: 	  Signature:
    TO: Barry Thierer, Region VH Supeifund Records Management Coordinator


    SUB J:  Supcrfund Site File Access Authorization    	New     	Revised

           Site Name: 	

           CERCLIS ED #:                               	
    Authorized Access

    •   Please note that the following individuals are members of the EPA Region VII Superfund site
        team. They are to be given full and complete access to all records comprising the above
        referenced site file.

            NAME                              TITLE

        	     Site Manager (RPM) - Region VII (SFFD)

        __;	     Attorney - Region Vn (COUNSL)
        The following individuals are officials of other government agencies or EPA support
        contractors involved with this site. They should be given full and complete access to all
        records comprising the above referenced site file.

                  NAME                          AFFTT.TATTQN
Model Regional Records Management Manual            (November 1991 draft)               95

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Records  Management  Program  Components
      Superfund Site File Access Authorization
      Page 2


      Authorized Access (cont'cL)


           The following individuals may be given limited access (e.g., CBI; only major break 2.0) to
           records comprising the site file shown on the preceding page, to the extent noted below.

               NAME                        AFFILIATION            TYPE OF ACCESS
      Special Note
           The access authorization set forth in this memorandum is in effect unless rescinded in writing
           by the site manager (RPM), the EPA Region VII site attorney, or a senior regional manager
           (e.g., section chief; branch chief; division director).
      Certification
           I have reviewed this memorandum and hereby certify that the individuals Listed are authorized
           to access this site's records, subject to the-limitations described, and pursuant to the Region's
           records management policies and procedures.
                        Section Chief                                         Date
 96                 (November 1991' draft)               Model Regional Records Management Manual

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                                                           Records Disposition
      4.  RECORDS DISPOSITION
            The  proper and  timely disposition  of  the region's records is
      critical to the success of a regional records management  program. A
      disposition plan assures the region of routine review of files no longer
      needed at the regional office, thereby increasing efficiency of records
      storage and maintenance, and retaining custodial control by the region.
      The implementation of  the disposition plan requires the support and
      oversight of  regional  records  officers. The  proper  disposition  of
      regional  records  refers  to  the destruction, retirement, or archival  of
      inactive records. The records officers help ensure that  the disposition
      process is  systematic and consistent.- Toward this  end,  the  records
      officers assist regional staff in categorizing records according  to
      established disposition schedules and assists in submitting records  to
      the Federal Records Center (FRC) for storage as  appropriate.

            Objective

                  The  objective of the disposition process is to relieve
            regional program  and general management staff of the burden of
            storing inactive records in the limited space available for records
            storage  and filing. To meet this  objective, the National Records
            Management  Program  (NRMP) has  established schedules  to
            guide the  regions in determining the  type of records to be
            disposed of, the appropriate disposal method,  and the timeframe
            for disposal. The  records officers  assist  regional  staff  in
            interpreting the Agency's disposition schedules and  meeting the
            disposition requirements.   This  section  outlines guidelines for
            the regional records officers in designing and implementing the
            disposition program.
            Legal/Administrative  Requirements

                  The  administrative and legal requirements  for  the
            region's records  disposition  program are established  by the
            Federal government and the Agency's NRMP. A listing of these
            requirements is presented on the next page.
Model Regional Records Management Manual           (November 1991  draft)             97

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Records Management  Program  Components
                           LEGAL AND ADMINISTRATIVE REQUIREMENTS
                                   FOR RECORDS DISPOSITION
                  Environmental Protection Agency,
                  Records Management Manual
                  Chapter 5, July 13. 1984
                  Public Law 95-440
                  Micrographics: 36 CFR Part
                  1230. July 2. 1990
                  Electronic RecordKeeping,
                  GSA. July 1989
                               Requires that inactive records
                               (whether program or
                               administrative) be disposed of at the
                               Agency or transferred to an FRC in
                               accordance with EPA Records
                               Control Schedules. Records should
                               not be maintained longer than 6
                               months after the time specified in
                               the records control schedule.
                               Requires Agency to develop and
                               apply lists and schedules for the
                               disposition and retention of
                               Agency records; also allows for
                               amendments to these schedules.
                               Requires Agency to develop and
                               maintain specific guidelines for the
                               disposition of microform records;
                               also establishes requirements for
                               micrographic records storage.
                               Requires special handling procedures
                               for long-term preservation of
                               electronic records.
              Additionally, 36  CFR, Chapter  XII (Subchapter B), provides
              NARA's  records   management  regulations  for  records
              maintenance and disposition by the FRC.

              Approaches

                    The disposition schedules  and FRC guidelines must be
              incorporated  into  the region's records disposition program.  The
              regional  records  officers  should take  the  following steps to
              design,  implement,  and  maintain  an  effective  disposition
              program:
98
(November 1991  draft)
Model Regional Records Management Manual

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                                                            Records Disposition
                   •     Define and categorize the region's general
                        management and programmatic records

                   •     Develop a plan to implement the Agency's
                        disposition schedule for regional records  and
                        update disposition schedules as necessary

                   •     Establish a working relationship with the FRC

                   •     Educate  program and administrative staff about the
                        records disposition process

                   •     Review the effectiveness of the records disposition
                        program.

                        Approaches for conducting these steps are discussed
                  below.

                         Define  and Categorize the Administrative and
                  Program  Records - EPA's  Office of Administration and
                  Resources  Management  (OARM)  issues disposition
                  schedules developed by the NRMP staff.  The Regional
                  Records Management Coordinator facilitates requests and
                  communications between regional  records officers and the
                  NRMP. The records disposition schedule classifies records
                  according to a  "series" of records (i.e., similar records are
                  grouped within a series) and explains what to do with the
                  records   in that  category  and  when to conduct such
                  activities.  The  records disposition schedule provides for
                  consistent and efficient transfer  to the FRC for  those
                  records no  longer needed for  day-to-day operations. To
                  determine the appropriate disposition requirements for a
                  record,  regional program and management  staff must
                  apply the series classification to the records generated or
                  maintained within the region.  The records officer acts as a
                  resource in this process, guiding regional staff in selecting
                  the relevant disposition schedule.   It is  critical that the
                  inactive  documents  be  identified   and  categorized
                  accurately and  with careful  consideration of the potential
                  administrative, legal,  fiscal,  scientific,  evidential, or
                  informational  value of  such records.  Therefore, the
                  regional  records officer must rely  on the creators and
                  initial users of the record, regional staff,  to identify the
                  region's inactive records.


Model Regional Records Management Manual            (November 1991 draft)             99

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Records Management Program Components
                        In consulting regional staff on inactive records, the
                  records officer has three disposition options to consider:

                        •     The record is listed in an approved
                              disposition schedule.  The records officer
                              helps owners and users agree with the
                              retention and disposition plans in the
                              schedule and then implements the
                              agreement.

                        •     The record is listed in an approved
                              disposition schedule, but owners and users
                              cannot agree that the plans for the retention
                              and/or disposition are appropriate. The
                              regional records officer consults with the
                              Regional Records Management Coordinator
                              on an appropriate remedy and, together, they
                              facilitate decisions by regional owners and
                              users.  If agreement cannot be reached at the
                              regional level, the Regional Records
                              Management Coordinator requests assistance
                              from  the NRMP in seeing resolution.

                        •     The record is not listed in an approved
                              disposition schedule.  The regional records
                              officer requests the assistance of the Regional
                              Records Management Coordinator in
                              requesting that the NRMP determine
                              whether it is appropriate to develop a new
                              series schedule to address the unique
                              characteristics of the regional  record in
                              question.  If the NRMP determines that the
                              regional record warrants a new or revised
                              schedule,  NRMP staff take the lead in
                              preparing the schedule and securing
                              appropriate approvals from Agency and FRC
                              managers.

                        A summary of  the standards used  to define the
                  value of a record is presented in the box below.  These
                  criteria are used by the NRMP in developing the records
                  schedules  and  are intended to provide the   regional
                  records management  staff  with  insight  into  the
                  disposition process.


100             (November 1991  draft)           Model Regional Records Management Manual

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                                                                  Records  Disposition
                                DETERMINING RECORD VALUE

                        It is the joint responsibility of EPA and the National
                        Archives and Records Administration (NARA) to
                        evaluate Agency records and determine appropriate
                        disposition schedules.  The Agency and NARA apply
                        the following definitions of "value" in determining
                        the schedule.

                        Primary Values: Those values of interest only to EPA,
                           specifically:

                        Administrative value - records that help  EPA  perform
                           its current work; they may have short or long-term
                           administrative  value

                        Legal value -  records containing evidence of legally
                           enforceable rights or obligations of the Agency

                        Fiscal value - records relevant to financial transactions.

                        Secondary Values:  Those values of interest to  both EPA and
                           others based on the long-range needs of research and
                           scholarship:

                        Evidential value • records  relating to Agency
                           organizational structure and functions; they provide
                           evidence  of EPA responsibilities and how they are
                           discharged

                        Informational value - records relevant to the
                           information created as a result of EPA programs.
                           Develop a Disposition Plan for Records and Update
                    Disposition Schedules as Necessary - This step is based on
                    the  groundwork laid  during  the  previous step1.  The
                    disposition plan relies on accurate, timely interpretation
         The design and implementation of the regional records disposition plan builds upon
         the understanding of the region's records gained through other records management
         activities, such as the performance of the file inventory, identification of vital
         records, and design of storage space to accommodate the records. Refer to the
         appropriate sections of this manual for further direction on the integration of these
         activities into the regional records disposition program.
Model Regional Records Management Manual
(November 1991 draft)
101

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Records Management Program  Components
                  and application of disposition schedules, which is based
                  on a clear and comprehensive inventory of the region's
                  records.  As liaison with  the  NRMP and the Regional
                  FRC, the Regional Records Management Coordinator is in
                  a position to assist records officers and their program and
                  general management managers in meeting current needs,
                  as well  as  anticipating future issues  related  to  records
                  retention. Steps  that  records officers should  take  to
                  promote  an accurate disposition  plan for records under
                  their responsibility are outlined below:

                        •      Develop and implement a  plan to  regularly
                              review records (i.e., determine the  types of
                              file materials, volume, and location of active
                              and inactive records and update the file
                              inventory). The actual use of program and
                              general management  records by owners and
                              users is checked to confirm the applicability
                              of retention and disposition plans, and,
                              where applicable, to note where current use
                              does not conform.  These facts support
                              decisions on applying schedules to the
                              region's records.

                        •      Fon*tard records covered by the schedule for
                              disposition or storage to the Regional FRC,
                              according to the plan specified in the
                              approved records disposition schedule.  The
                              records officer will complete SF-135, Records
                              Transmittal and Receipt, to submit records to
                              the Regional FRC through the  Regional
                              Records Management Coordinator. The  FRC
                              will only accept records with an approved
                              records disposition schedule. A photocopy of
                              the SF-135 is attached at the end of this
                              discussion.

                        •     Coordinate requests for the retrieval of
                              regional records stored at the Regional FRC.
                              The records officer will coordinate regional
                              staff requests for retrieval  through the
                              Regional  Records Management Coordinator.
                              This consultation ensures  that the requests
                              are reasonable and in accordance with
                              records retrieval arrangements established


102             (November 1991 draft)            Model Regional Records Management Manual

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                                                           Records  Disposition
                              with the FRC. For each retrieval request, the
                              records officer assists regional staff in
                              completing Option Form 11, Reference
                              Request — Federal Records Centers. A
                              photocopy of this form is attached at the end
                              of this chapter.

                        •     Draft a proposed schedule for regional
                              records not covered by existing schedules or
                              for which existing retention and/or
                              disposition are no longer suitable. This
                              proposal reflects the information gained
                              during the file inventory and from owner's
                              and users's feedback on the current use and
                              value of the record.  The form to be used for
                              transmitting the draft schedule from the
                              Regional Records Management  Coordinator
                              to the NRMP is form SF-115, Request for
                              Records Disposition Authority.  A photocopy
                              of SF-115 is attached at the end of this
                              chapter.

                        •    -Submit the draft schedule through the
                              Regional Records Management  Coordinator
                              to the NRMP for review and concurrence.
                              Upon receipt and approval, the  NRMP
                              manager will, in turn, submit the draft for
                              approval within EPA and by NARA.
                              Internal approval will consider  whether all
                              relevant records are covered, non-record
                              materials are covered, the retention period is
                              adequate, and descriptions are clear.

                  Each of these steps must be implemented in  concert with
                  the program  and  general management staff,  i.e.,  the
                  creators and initial users of the records, to ensure ultimate
                  accessibility of records and efficient use of FRC resources
                  and services.  The chart on the next page illustrates the
                  interactions  of  key  regional and  national  records
                  management programs,  the  FRC,  and regional  records
                  creators and users, as  well as the role such interactions
                  play in the disposition process.
Model Regional Records Management Manual           (November 1991 draft)             103

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Records Management Program  Components
          Records Disposition Process - Roles & Responsibilities




Regional
Records
Management
Coordinator



Regional
Program and
Administra-
tive Staff





Regional
Records
Officers




National
Records
Management
Program
Manager





Federal
Records
Center
(NARA)





Conduct
Required
Records
Inventory
Coordinates
regional records
management
resources and
communications
with National
Records
Management
Program and
Regional Managers

Reviews program
and administrative
records for
inventory
Provides insight
regarding creation
and use of program
and administrative
records
Guides other
regional staff in
defining records
and identifying
appropriate storage
options

Provides guidance,
as needed, to the
Regional Records
Management
Coordinator
regarding records
classification







-





Develop/Update
Disposition Schedules


Guides preparation of
schedules
Submits draft/updated
schedule to National
Records Management
Program Manager for
approval
Communicates schedule
approval to involved parties

Defines records series to
be used in Agency records
schedules
Notifies regional records
officers of need for
schedule updates



Prepares draft/updated
schedule for the regional
and national review - SF 11 5




Reviews draft/updated
disposition schedule and
obtains necessary approval
Acts as liaison with region,
NARA, & national program
Coordinates with Agency's
directives system to ensure
appropriate Agency-wide
knowledge or new updated
records schedules









Forwards Records
to FRC


Acts as regional contact
with FRC
Reviews SF-135for
consistency •
Communicates FRC
procedures and
standards to regional
staff
Communicates regional
needs to FRC
Prepares back-ground
information to be
included in the SF-135
Prepares package
materials to be
forwarded to FRC



Prepares SF-135, in
concert with program/
administrative staff

Guides regional staff in
preparing records for
shipment
Communicates any
exceptions to
schedules to the FRC,
based on input from
Regional Records
Management
Coordinator




Reviews SF-135 upon
receipt of schedules
records, to ensure
consistency with
schedule and FRC
procedures



Retrieval of
Records from FRC


Coordinates retrieval
requests and ensures
consistency with FRC
procedures
Communicates
procedural issues or
changes to regional and
FRC contacts


Prepares retrieval
requests in timely
manner (Optional Form
11)





Provides guidance to
regional staff in
preparing retrieval
requests (Optional Form
")


Supports Regional
Records Management
Coordinator in resolving
access/ storage issues,
as necessary





Supports Regional
Records Management
Coordinator in
understanding FRC
function and procedures

Assists in resolving
procedural issues
regarding FRC

-------
                                                            Records  Disposition
                         The regional records officers must rely on regional
                   staff to distinguish between  the  region's active and
                   inactive records. With accurate assessments of the records
                   disposition needs,  the  records  officers can ensure the
                   necessary  level of user access and  control  over  Agency
                   records.

                   Establish a Working Relationship with the FRC - The U.S.
                   Government's Federal Records Centers are operated by the
                   National Archival and Records Administration (NARA).
                   An  FRC is located in each of  the  EPA Regions.  The
                   mission of the FRC  is to provide economical storage and
                   servicing of non-current or inactive records for  Federal
                   agencies,  pending  their  deposit in the U.S. National
                   Archives or other disposition authorized by law.  EPA is
                   only one of approximately 93 Federal agencies forwarding
                   records to the FRC; nearly two-thirds of the records belong
                   to  the Internal Revenue  Service  and Social  Security
                   Administration.   With such a  large volume and broad
                   range of records, the FRC has  established a system  of
                   uniform storage and  retrieval  procedures  to maximize
                   storage efficiency and insure Agency access to records.

                         As the  region's primary contact  with the FRC, the
                   Regional Records Management Coordinator is responsible
                   for  ensuring  that FRC  standards  and definitions are
                   properly applied to Regional records. It is essential to the
                   proper and efficient operation of the region's disposition
                   program  that  the Regional  Records  Management
                   Coordinator understands fully the FRC requirements and
                   expectations and maintains routine communication  with
                   the FRC.

                        Specific  functions or terms that the regional
                   coordinator   should   clarify   with   the  FRC   and
                   communicate  to Regional staff include:

                         •     Definition of "inactive" files, i.e., whether
                              records being transferred to the FRC are used
                              quarterly, annually, etc.2
      2   Generally, more than one retrieval per box per month is considered an active record.
          Regional records officers should work with the FRC to further define activities vs.
          inactive records for their region.


Model Regional Records Management Manual          (November 1991 draft)             105

-------
Records  Management  Program  Components
                                Exceptions or updates to the records
                                schedules, as discussed with the NRMP
                                Selection of files for transfer to the FRC
                                (including proper forms)
                                Preparation of files for transfer to the FRC
                                Accessing the FRC reference service
                                (including forms and timeframes)
                                Disposal of records eligible for destruction.
                                HINTS FOR ESTABLISHING A
                            WORKING RELATIONSHIP WITH THE
                                 FEDERAL RECORDS CENTER

                      Visit the FRC.  Establish personal contact with the FRC to
                         understand their requirements for packing and
                         labelling records such as materials to be used,
                         standards for completing the SF135 or 135-A forms,
                         and numbering sequence for boxes.  It may also be
                         helpful to understand the other functions and services
                         provided by the FRC, such as disposal of records and
                         micrographic services. Pass this understanding along
                         to other regional staff.

                      Take advantage of  FRC-sponsored workshops.  The FRC
                         periodically offers workshops for Agency users.  Such
                         workshops provide  general, government-wide
                         procedures on using the FRC effectively.  Refer to the
                         FRC serving your region for additional information
                         regarding workshop topics, timing, and costs.

                      Be consistent in making  requests.  Determine  whether  the
                         region will require the FRC to retrieve information at
                         the box, document or file level. Document level
                         retrieval may require additional preparation/indexing
                         of files being forwarded to the FRC.

                      Do not retire high-activity records.   Encourage regional
                         staff to evaluate accurately the usage level of records.
                         The FRC should not be responsible for continuous
                         retrieval of frequently used documents; these
                         documents should be retained by the region.
106
(November 1991 draft)
Model Regional Records Management Manual

-------
                                                          Records  Disposition
                        Because FRC requirements may vary across regions,
                  it  is  essential  that  the Regional Records Manager
                  Coordinator address these issues with the FRC  contact.
                  For a list of FRC contacts see pages 115-117.

                        Educate Program and Management Staff about the
                  Records Disposition Process -  The regional  records
                  management staff is responsible for communicating FRC
                  requirements  and  expectations as  well as providing
                  information about  the Agency's  disposition schedules.
                  The regional records officers should ensure that regional
                  staff understand and  apply this information  in defining
                  inactive records   and  determining  an  appropriate
                 -disposition or  retention alternative.

                        In communicating  information about FRC storage
                  requirements  and  procedures,  the regional  records
                  managers  should  emphasize to  regional  staff  that
                  submission of  records to  the FRC or the regional records
                  centers for storage does allow for timely retrieval of those
                  records, as needed. Regional staff should be apprised of the
                  appropriate procedures for requesting documents, as well
                  as  the appropriate  timeframe  for receipt of information
                  stored at the FRC or in the region.

                        Review the Effectiveness of the Records Disposition
                  Program   -  The  Regional Records  Management
                  Coordinator should  take the lead in  evaluating  the
                  effectiveness of the  region's records disposition program.
                  Recprds officers should  evaluate the office they serve.
                  Because the impacts of program success or limitation will
                  be  felt primarily by  the program and administrative staff,
                  these  regional staff  should  be  involved  directly  in
                  evaluating the program.  Some measures  of effectiveness
                  for the records disposition program include:

                        •    Volume of records being forwarded to the
                             FRC

                        •    Volume of inactive records in regional
                             records centers
                              Awareness of program by regional staff, in
                              terms of type or number of questions asked
Model Regional Records Management Manual          (November 1991 draft)             107

-------
Records Management  Program  Components
                           •     Ease in records storage due to use of
                                 alternative storage or disposal of unneeded
                                 records.

                           These measures  will  support the implementation
                    and maintenance of a  records disposition program that
                    meets the  ultimate objective of  reducing  the volume of
                    inactive records maintained by regional staff.
                           The Office of the Future environment will facilitate  the
                        necessary interactions  among  the  several parties sharing
                        information in the disposition process. Technology innovations,
                        such as local area networks, which can be used to communicate
                        information about record inventories and disposition schedules,
                        arc feasible alternatives for the disposition process.  Such
                        technology is not only an appropriate method for efficiently
                        meeting disposition schedules, but is also a means of:

                           •  Decreasing staff work burden

                           •  Removing barriers to information sharing between
                              national and regional programs

                           •  Broadening information access across Regions

                           The National Records Management Program Manager  is
                        moving forward with such technological innovations, and will
                        be working with regional records management staff to explore
                        further  ways to use technology to meet the aforementioned
                        disposition objectives.
W8
(November 1991  draft)
Model Regional Records Management Manual

-------
                                                 Records  Disposition
                        ATTACHMENTS
               •    Standard Form 115, Request for Records
                    Disposition Authority

               •    Standard Form 135, Records Transmittal
                    and Receipt

               •    Optional Form 11, Reference Request -
                    Federal Records Centers

               •    Federal Archives and Records Center
                    Locations

               •    Regions of the National Archives and Records
                    Aministration
Model Regional Records Management Manual         (November 1991 draft)           W9

-------
                                    Records Disposition
Standard Form 115, Request for Records
          Disposition Authority


REQUEST FOR RECORDS DISPOSITION AUTHORITY LEAVE BLANK

TO. GENE
NATION
fi** inttructlont on r«v«rt«; Me HO
RAL SERVICES ADMINISTRATION,
U. ARCHIVES AND RECORDS SERVICE. WASHINCION. DC 20401 OArE' RECe,v€o 	


1. FFKX (AGENCY OH ESTABLISHMENT)

	 	 NOTlFlCATmN TO Ar.tMTY
J. MAJOFI SUBCHVISMX 	 	 ' 	
M KortHKt "I* l*» imrvem it M U S C 3J03J m *s«iii it
qutil uvludi«it jrmiwmmt ft jaoiovcd eit«M to* items llut nuv
3 MINOR SUBDIVISION X 5l*»l «o
( inxiMrt o. ..w«. - coi^- 10
4 NAMrJ OF PERSON WITH WHOM TO CONFER 1. TEL EXT


« CERTIFICATE Of AGENCY REPRESENTATIVE
1 hereby certify that 1 am authorized to act for this agency in matters pertaining to the disposal of the agency's records;
that the records proposed for disposal in this Request of 	 page(s) are not now needed for the business of
this agency or will not be needed after the retention periods specified.
G A Request for immediate disposal.
G B Request 'or disposal after a specified period of time or request for permanent
retention
C DATE
7.
ITEM NO

0 SIGNATURE Of AGENCY REPRESENTATIVE e HUE
« DESCRIPTION Of ITEM
(Wim lnclu»i«« O«l«« or A««««H*on F*«nodal

^eV -c«i'-«

Mi. 107 STANDARD FORM lit
B.....O Ap. , 1975
Pr«*cntMd OY Gtnvffl Servtc**
Aommislnlion
FPMO {41 CFP) 101-11 *

-------
Records  Management  Program  Components
                                   INSTRUCTIONS
GENERAL
Use Standard Form 115 to obtain authority for the
disposition of records. Submit two signed copies to
the National Archives and Records Administration
(N1R), Washington, DC 20408, and retain one copy as
your suspense copy. NARA will later return one
copy as notification of the items approved for
disposal or archival (permanent) retention. This
copy will also indicate any items withdrawn or
disapproved. GAO's written approval must either
accompany each SF 115 requiring Comptroller
General concurrence or be requested prior to the
submission of the SF 115 to NARA.  The SF 115 may
be  accompanied by Standard Form 115A,
Continuation Sheet, by schedule items entered on
blank stationery formatted similar to the SF 115A, or
by pages  formatted to conform to the agency's
published records disposition schedule.
SPECIFIC

Entry 1 should show the name of the Executive
Branch department or independent agency,
Legislative Branch agency, or trie Administrative
Office of the U. S. Courts for the Judicial Branch that
is submitting the request.

Entries 2 and 3 should show the major and minor
organizational subdivisions that create or maintain
the records described on the form. If more than one
subdivision maintains records described in the
submission, the various office names should be
specified in entry 8.

Entricf'4  and 5 should provide the  name and
telephone  number of the person to be contacted for
information.

Entry 6 must be signed and dated by the  agency
official authorized to certify that the retention
periods for records proposed for disposal are
adequate to meet the agency's needs,  and that GAO
requirements have been met (check appropriate box).
Unsigned SFs 115 will be returned to the agency.

Entry 7 should contain the item numbers of the
records identified on the form in sequence, beginning
with "1."   Lower case, letters and numbers  may be
used to designate subdivisions of an item  (la, Ib,
lb(l), lb(2), etc.). Agency file numbers should not be
entered in this column, but may be included in entry 8.

Entry 8 should describe the records to be scheduled.
Follow these steps in describing the records:

     (a) Include centered headings for croups of
items to indicate the  office of origin if  ail  records
described on the form are not those of the  same
office, or if they are records created by another office
or agency such as, for example, records inherited
from a defunct agency.
                                  (b)  Identify separate collections of nontextual
                              records, such as photographs, sound  recordings,
                              maps, architectural drawings, or magnetic tapes or
                              disks, as separate and distinct items. If such records
                              are interspersed with textual records, as  in case files,
                              their presence should be noted in the description of
                              the textual file.

                                  (c)  Describe completely and accurately each
                              series of records proposed for disposal or transfer to
                              the National Archives.  See 36 C.FR 1228 for more
                              detailed requirements.  Failure to comply with the
                              provisions of that regulation will result in the return
                              of the SF 115 for corrective action.

                                  (d)  Provide clear disposition instructions for
                              each item and subitem.  Tnese instructions should
                              include file breaks; the time after which  records will
                              be retired to Federal records centers, if applicable;
                              for temporary records, the time after which they may
                              be destroyed; and  for archival (permanent)  records',
                              the time after which they will be transferred to the
                              legal custody of the National Archives.

                                  (e)  If immediate disposal or transfer to the
                              National Archives is proposed for non-recurring
                              records, indicate the volume and inclusive  dates ot
                              the records and the Federal records center accession
                              and box numbers, if applicable.

                                  (0 If future or continuing disposition authority
                              is requested, state the retention period  in terms of
                              years,  months, etc. or in terms ot future actions or
                              events. Ensure that  any future action or event that
                              must precede final disposition is objective and
                              definite.

                                  (g)  If records are converted to electronic form,
                              schedule both the original records and the electronic
                              media, unless covered by the General Records
                              Schedules.

                                  (h)  If  permanent or unscheduled  records are
                              converted to microform, the disposition  for both the
                              original and microform copies must be approved on
                              an SF 115. The SF  115 covering the microform must
                              contain the certifications required by 36 CFR 1230.
                              Approval is  not required tor the disposition of
                              microform copies of records authorized tor disposal,
                              as specified in the regulation cited above.
                              Entry 9 must include the previous NARA disposition
                              job and item numbers; General Records Schedule
                              and item numbers, if applicable; and agency
                              directive or manual and item numbers, if applicable,
                              as required by 36 CFR 1228. If such information is
                              missing from column 9, the SF 115 will be returned
                              without action.  Leave column 9  blank only if the
                              records are being scheduled for the first time.

                              Entry 10 is for NARA use only and should  be left
                              blank.
                                                     STANOAHO FORM 1TS BACK (REV 3-91)
112
(November  1991  draft)
Model Regional  Records Management Manual

-------
                                               Records Disposition
       Standard  Form  135,  Records Transmittal
                        and  Receipt
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            (November 1991 draft)        Model Regional Records Management Manual

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                                                                               Records  Disposition
                   Optional   Form  11,  Reference  Request  -
                                Federal   Records   Centers
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                                                               Records Disposition
                            Federal   Archives
                  and  Records  Center  Locations
            The addresses and phone numbers for the Federal records
            centers are listed below. Area served by each center are
            noted in parentheses.
Boston Federal Records Center
(Maine, Vermont, New Hampshire,
Massachusetts, Connecticut, Rhode Island)
380 Trapelo Road
Waltham, MA 02154
617-647-8745
FTS 839-7745

New York Federal Records Center
(New York, New Jersey, Puerto Rico,
the Virgin Islands, Panama Canal Zone)
Building 22, Military Ocean Terminal
  ayonne,NJ  07002-5388
   -823-71 61
Philadelphia Federal Records Center
(Delaware, U.S. court records for Maryland,
Pennsylvania, Virginia, West Virginia)
5000 Wissahickon Avenue
Philadelphia, PA  19144
215-951-5588
FTS 486-5588
Atlanta Federal Records Center
(North Carolina, South Carolina, Tennessee,
Mississippi, Alabama, Georgia, Florida, Kentucky)
1557 St. Joseph  Avenue
East Point, GA  30344
404-763-7438
FTS 246-7438
Chicago Federal Records Center
(Illinois, Wisconsin, Minnesota; and U.S. court
records for Indiana, Michigan, Ohio)
7358 South Pulaski Road
Chicago,IL 60629
312-353-0164
FTS 353-0164

Dayton Federal Records Center
(Indiana, Michigan, Ohio, except
U.S. court records)
3150 Springboro Road
Dayton, OH 45439
513-225-2878
FTS 774-2878

Kansas City Federal Records Center
(Kansas, Iowa, Nebraska, Missouri except
greater St. Louis area)
2312 East Bannister Road
Kansas City, MO 64131
816-926-7272
FTS 926-7272

Fort Worth Federal Records Center
(Texas, Oklahoma, Arkansas; Louisiana, New
Mexico)
P.O. Box 6216
Fort Worth, TX 76115
817-334-5515
FTS 334-5515
 Model Regional  Records Management  Manual
     (November 1991 draft)
111

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Records  Management  Program  Components
    Denver Federal Records Center
    (Colorado, Wyoming, Utah, Montana,
    North Dakota, South Dakota)
    Denver Federal Center, Bldg. 48
    P.O. Box 80225
    Denver, CO 80225
    303-236-0804
    FTS 776-0804

    Los Angeles Federal Records Center
    (Arizona, Clark County, Nevada, Southern
    California)
    24000 Avila Road, 1st Floor
    Laguna Miguel, CA 92607-6719
    714-643^220
    FTS 796-4220

    San Francisco Federal Records Center
    (American Samoa, California, except Southern
    California, Nevada, except Clark County)
    1000 Commodore Drive
    San Bruno, CA 94066
    415-876-9015
    FTS 470-9015

    Seattle Federal Records Center
    (Washington, Oregon, Idaho, Alaska, Hawaii,
    Pacific Ocean areas, except American Samoa)
    6125 Sand Point Way, NE
    Seattle,WA 98115
    206-526-6501
    FTS 392-6501
                               -NATIONAL CENTERS

                               Washington National Records Center
                               (District of Columbia, Maryland, Virginia,
                               West Virginia,  except U.S. court records
                               for Maryland, Virginia, and West Virginia)
                               4205 Suitland Road
                               Suitland, MD 20409
                               301-763-7000
                               FTS 763-7000

                               National Personnel Records Center
                               (Records of separated military and civilian
                               personnel and other designated records)
                               9700 Page Boulevard
                               St. Louis, MO 63132
                               314-538-4201
                               FTS 538-4201

                               National Personnel Records Center
                               (Designated records of the Department of
                               Defense and the U.S. Coast Guard personnel records)
                               Military Personnel Records
                               9700 Page Boulevard
                               St. Louis, MO 63132
                               314-538-4246
                               FTS 538-4246

                               National Personnel Records Center
                               (Entire Federal Government personnel records
                               of separated Federal employees; pay records of
                               all Federal employees; medical records of
                               civilian employees of the Army, Navy and Air Force;
                               records of agencies in the greater St. Louis, MO area)
                               Civilian Personnel Records
                               111 Winnebago Street
                               St. Louis, MO 63118
                               314-425-5722 "
                               FTS 279-5722
IIS
(November  1991 draft)
Model  Regional Records Management Manual

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                                                Records  Disposition
          Regions  of the  National  Archives
             and  Records  Administration
Model Regional Records Management Manual
(November 1991 draft)
719

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Records  Management  Program Components
120             (November 1991  draft)           Model Regional Records Management Manual

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                                                               Vital Records
      5.   IDENTIFYING AND MAINTAINING VITAL
           RECORDS
            Vital records may be defined as (1) those records essential to the
      continued  functioning of an  organization  during  and  after an
      emergency, and (2) those records essential to the protection of the rights
      and  interests of the federal government and of the individuals for
      whose rights and  interests it has responsibility. In order to  ensure
      preservation of the Agency's vital records, the records officers  should
      work with regional staff to develop procedures that will protect records
      classified as vital from  loss  through deterioration, water damage, fire,
      smoke and other potential hazards.   It is  the  responsibility  of the
      records  officers  under  the direction  of  the Regional Records
      Management Coordinator to develop viable and specialized storage
      preservation  requirements  that  integrate program objectives.  This
      section outlines guidelines for developing such requirements.

            Objective

                  The primary objective of the vital records  program is to
            provide a systematic method for safeguarding  the records
            defined as critical to  the  continuing operation  of essential
            Agency functions  during  a  national emergency or  to  the
            protection of rights  and interests.

            Legal /Administrative  Requirements

                 The administrative  and  legal requirements for  the
            region's vital records program are established by  the federal
            government and EPA.  A  listing of these  requirements is
            presented on the next  page.
Model Regional Records Management Manual           (November 1991 draft)             121

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Records Management Program  Components
                          LEGAtT AND" ADMINISTRATIVE REQUIREMENi
                               ,   GOVERNING VITAL RECORDS
                  Assignment of Emergency
                  Preparedness Responsibilities,
                  E.O. 16256
                   Computer Security Act of 1987,
                   Public Law 100-235
                  Environmental Protection Agency
                  Records Management Manual.
                  Chapter 4. 1984
                  Vital Records During an Emergency.
                  36 CFR Part 1236
                                 Requires Federal agencies to
                                 implement national security
                                 emergency preparedness
                                 functions and activities, including
                                 plans, policies, procedures, and
                                 readiness measures
                                 Requires Regions to implement
                                 techniques to facilitate cost
                                 effective security and privacy of
                                 sensitive information in Federal
                                 computer systems
                                 Requires Regions to establish
                                 procedures for identifying and
                                 maintaining vital records and to
                                 submit regular reports on the
                                 vital records program to EPA
                                 Headquarters
                                 Requires the design of a simple
                                 and concise vital records
                                 program with upper management
                                 cooperation and support;
                                 requires annual review of the vital
                                 records program
              Approaches

                     In  designing  a system for  tracking and  storing vital
              records, the regional records officer should consider the special
              needs of the Agency's numerous and varied operating programs.
              Specifically, the  records officers should take  the  lead  in  the
              following activities  to  implement  a  regional vital  records
              program:

                     •      Plan and staff the vital  records program
122
(November 1991 draft)
Model Regional Records Management Manual

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                                                                  Vital Records
                  •     Identify vital records

                  •     Develop procedures for managing vital records

                  •     Select a storage facility for maintaining vital records

                  •     Promote the vital records program

                  •     Review the effectiveness of the vital records
                        program.

                  These function are explained below.

                        Plan  and Staff  the  Vital  Records  Program  - In
                  planning for the  region's centralized  vital records
                  program, the Regional Records Management Coordinator
                  takes the lead  in  defining the region's tracking  and
                  maintenance standards  for vital records in consultatation
                  with the records officers.  These standards should take
                  into  account  programmatic  and   administrative
                  requirements for  records  management,  such as  the
                  following:

                        •     Location of vital records files or storage
                              facilities

                        •     Common use vs. specific use files

                        •     Program-mandated  organization and
                              labelling of files

                        •     Frequency of file use and updates

                        These  requirements  will be identified  by  the
                  program and administrative staff as they define the vital
                  records generated or  held in their offices.   The records
                  center staff may provide guidance or assist the program
                  and management staff  in understanding how to  define
                  vital records; however it is  critical  that the vital records
                  ultimately be defined by the generators and users of those
                  records.  Consideration of the   programmatic  and
                  administrative requirements in  setting up the centralized
                  vital records program will increase  its effectiveness  and
                  enhance the  region's  ability to  manage the program at
                  minimal cost and effort to the region.


Model Regional Records Management Manual           (November 1991 draft)             123

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Records  Management Program  Components
                         There are  federal requirements  designating  the
                   involvement of certain  staff in  the regional vital  records
                   program.   These  personnel, along  with  their primary
                   responsibilities to the vital records function, are presented
                   below.
                         KEY REGIONAL RECORDS MANAGEMENT
                      PERSONNEL INVOLVED IN THE VITAL RECORDS
                                          PROGRAM

                      EPA Emergency Preparedness Coordinator:*  Develops
                         and maintains a multi-year national emergency
                         preparedness plan that outlines objectives, programs,
                         and budgetary requirements. Communicates vital
                         records functions to regional records managers and
                         assists upper management across Agency programs in
                         developing uniform standards for identifying, tracking,
                         and maintaining the safekeeping  of vital records.

                      EPA Records Management Coordinator:  Works directly
                         with EPA's Emergency Preparedness Coordinator,
                         regional records officers, and the region's Vital Records •
                         Officer in developing appropriate and proven records
                         management methods for defining and protecting the
                         region's vital records.  Coordinates records management
                         and vital records protection functions across regional
                         offices.

                      Records Officers:  Provide  management and programmatic
                         support to the implementation and maintenance of the
                         vital records program.  Assists in developing viable
                         standards for identifying and preserving the region's
                         vital records and ensuring that the standards reflect
                         program requirements and resources.

                      Vital Records Officer:  Leads the region in developing
                         programs to train and educate program staff in the
                         proper handling, storage, and identification of vital
                         records. Assesses the region's vital records program and
                         ensures that the program conforms to federal and EPA
                         requirements.

                      *  This is a senior policy official designated by EPA
                         Headquarters.
124
(November 1991 draft)
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                                                                  Vital Records
                        The regional records management staff will interact
                   with each of these personnel in supporting an effective
                   vital records program.
                        Identifying  Vital  Records - To meet the range of
                  programmatic and administrative considerations that
                  make the vital records program an integral part of the
                  region's records management program,  regions  should
                  adopt a twofold approach in identifying records to  be
                  included in the vital records program:

                        •     Identify the types and quantities of records
                              deemed vital to the ongoing operation of the
                              Agency in the event of natural disaster or
                              loss of other records or information storage
                              systems

                        •     Assess the types of storage necessary to
                              safeguard these records.

                        This approach will  assist  the region in meeting the
                  overall objective of protecting the integrity of and access to
                  the records that are  an  integral part of the Agency's
                  operating functions.

                        To assist the regions in identifying vital records, the
                  Code of Federal Regulations (CFR) provides two general
                  categories for distinguishing  vital records:   emergency
                  operating records and rights  and interests records. The
                  regional records  officers should assist program and
                  general  management staff  in defining  their  records
                  according to these standards.

                        Emergency operating records are defined as those
                  records vital  to  the  essential functions  of  the  Federal
                  Government (or in  this case EPA) for  the duration of an
                  emergency  if the country is  attacked.  Because these
                  records include those necessary for maintaining public
                  health and  safety, the records for maintaining the nation's
                  environmental programs are included herein.  The CFR
Model Regional Records Management Manual           (November 1991 draft)             125

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Records Management  Program  Components
                  prescribes that these records must be available as needed at
                  or in the vicinity of emergency operating centers.3

                        Rights and  interests  records are those records
                  essential  to the preservation of the legal rights and
                  interests of individual citizens  and their  government.
                  The payroll and administrative records of the Agency, as
                  well as legal proceedings and decisions, are included in
                  this category.   The rights  and interests records require
                  protection, but storage points do not have to be at or in the
                  vicinity of emergency operating centers.

                        Develop  Operating Procedures - The  Regional
                  Records Management Coordinator  should   establish
                  specific  standards and operating  procedures  for vital
                  records that are distinct from the handling procedures of
                  routine records.  The vital  records procedures should
                  consider  the type  of storage or  access requirements
                  identified by the  program and administrative  staff.  A
                  sample procedures checklist for handling vital records is
                  included as an attachment at the end of this section..

                        Select a Storage Facility - The storage facility for
                  vital records is selected by  the records management staff.
                  Integrating an  understanding of the types of records,
                  necessary accessibility for the records, and the volume of
                  records, the records  management staff selects a storage
                  facility or  storage equipment to be housed off-site or
                  within  the  regional offices. One  storage option for vital
                  records is at one of the regional FRCs.

                        References

                        Evaluating a Vital Records Program. A NARS
                        Self-Inspection Guide for Federal Agencies. 1983.

                        Provide Information Resources to Program and
                  Administrative  Staff - The records management  staff may
                  be  requested to respond to questions from the program
                  and administrative staff as they identify vital records.  The
      3   Emergency operating centers, as presented in 36 CFR Part 1236, are facilities
          designated in the event of national emergency as the centers of operations for
          Federal government functions and the storage locations for the Federal
          government's vital records relevant to carrying out essential functions.


126             (November  1991 draft)           Model Regional Records Management Manual

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                                                                Vital Records
                  records management  staff  should  take  the lead  in
                  providing  such support  to  ensure  that identification
                  standards  are  consistent  and  that  program  and
                  administrative requirements  for access  and storage are
                  clear.

                        Review the Effectiveness  of the Program - The
                  records management  staff  should  take  the lead  in
                  evaluating  the effectiveness of the vital records program
                  by  reviewing materials to  ensure  that  program and
                  administrative staff are participating in the program and
                  to understand the objectives of the vital records program.
                  Where there  are lapses in  the effectiveness of the vital
                  records program, the records management staff should
                  meet with the program or administrative offices affected
                  to review vital records procedures and solicit feedback to
                  improve procedures,  as  appropriate.  The  Regional
                  Records  Management  Coordinator  should  routinely
                  review the  effectiveness of the overall regional program,
                  as well as  any broader issues based  on the Federal  or
                  Agency-wide policies,  for  discussion with  the  EPA
                  Emergency  Preparedness Coordinator.
Model Regional Records Management Manual           (November 1991 draft)             127

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Records  Management  Program Components
128             (November 1991  draft)           Model Regional Records Management Manual

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                                                   Vital  Records
                      ATTACHMENTS
                   Checklist of Activities for Implementing a
                   Regional Vital Records Program

                   36 CFR CHAPTER XII, SUBCHAPTER B,
                   Part 1236 - Vital Records During an
                   Emergency

                   EPA Vital Record Plan, Records Management
                   Manual, 1984
Model Regional Records Management Manual        (November 1991 draft)           129

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Records  Management  Program  Components
130             (November 1991 draft)            Model Regional Records Management Manual

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                                                                Vital Records
         Checklist of  Activities  for  Implementing
             a  Regional  Vital  Records Program
            The following checklist presents the complete range of questions
      that must  be addressed in implementing a regional vital records
      program.   Responsibility for these issues is shared among regional
      records officers and the owners and users of records.

                  Planning and Staffing the Program

                  	    Have the essential functions  of the regional
                           office been defined?

                           Have the potential threats to the region's vital
                           records been assessed?

                           Has a Vital Records Officer been designated to
                           work with  program  and administrative staff in
                           the implementation  of the Regional program?

                  Identifying Vital Records

                           Are vital records designated in conducting the
                           records inventory?

                  	    Are emergency operating records  defined and
                           designated in the region's file structures?

                           Are rights and interests records defined and
                           designated in the region's file structures?

                  	    Does the  region have a policy for  handling
                           duplicates of vital records?

                           Does the region have a policy for safeguarding
                           vital records that are stored in electronic
                           recordkeeping systems?
Model Regional Records Management Manual           (November 1991  draft)             131

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Records Management  Program  Components
                  Developing Operating Procedures

                  	    Is there a central, complete, and up-to-date set of
                            inventories for emergency operating and rights
                            and interests records?

                  	    Are vital records arranged and indexed in a
                            method  that is consistent with programmatic
                            and administrative requirements regarding
                            access, organization, and storage?

                  	    Are records maintained for rights and interests
                            purposes filed separately from records kept for
                            emergency operations, especially if the
                            combined volume would  create a  storage
                            problem for the region?

                            Have arrangements been made for the use of
                            electronic records/files in the event that special
                            equipment is necessary to use emergency
                            operating records?

                            Are designated vital records that are in machine
                            readable form accompanied by textual
                            documentation?

                  Selecting a Storage Facility

                            Is the storage facility for emergency operating
                            records located at or near the regional office?

                            Is the  facility fire resistive? Does it have
                            adequate fire procedures and protection
                            features?

                            Does the facility have adequate power sources  to
                            operate electronic recordkeeping equipment, if
                            that is necessary to read emergency operating
                            records?

                            Are there special areas in the alternate facility
                            for the storage of classified or sensitive material?
132             (November 1991 draft)            Model Regional Records Management Manual

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                                                                   Vital Records
                            Does the facility offer inventory control,
                            microfilming, reference service, or other records
                            management assistance?
                   Provide Information Resources

                   	    Are regular reports on the Regional vital records
                            program submitted to Headquarters?

                   	    Have all regional personnel responsible for
                            managing and operating the vital records
                            program properly trained?

                            Are records management staff able to answer
                            questions and provide assistance to staff in
                            inventorying records to be included in  the vital
                            records program?

                   Reviewing the Effectiveness of the Program

                            Is the region's  vital records program reviewed
                            on an annual basis?

                            Are vital records procedures simple, concise,
                            and economical for records management staff?

            These questions  are not intended to  be exhaustive but rather to
      guide the region in assessing the level of effort and resources  necessary
      to implement the vital  records program.
Model Regional Records Management Manual           (November 1991 draft)              133

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 Records  Management  Program  Components
Part 1236-Vital Records
During an Emergency
  Sec.
  1236.1
  1236.2
  1236.4
  1236.6
  1236.8
Purpose.
Background.
Categories of vital records.
Program considerations.
Vital records storage at Federal records
centers.
  AUTHORITY: 44 U.S.C 2104
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    Federal Records Management Laws and Regulations

      desiring to store these records, m addition to        (b) Agencies may make arrangements for the
      storage space for paper records, each N ARA        transfer of their rights and interests records to
      records center has environmentally controlled       any of the records centers by contacting the
      space suitable for the storage of vital records        appropriate center director or the Office of
      on magnetic tape and photographic film.           Federal Records Centers (mailing address:
                                                     National Archives (NC), Washington, DC
                                                     20408).
                                                     (43 FR 43461, Sept. 26,1978. Redesignated and
                                                     amended at 50 FR 15723,15725, Apr. 19,1985, fur-
                                                     ther amended at 51 FR 23538, June 30, 1986]
Model Regional Records Management Manual             (November 1991 draft)                135

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Records  Management  Program Components
136             (November 1991 draft)           Model Regional Records Management Manual

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Vital Records
EPA Vital Record Plan,
Records Management Manual, 1984



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Records  Management Program  Components
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Records  Management Program  Components
144             (November 1991 draft)            Model Regional Records Management Manual

-------
                                                         Information  Security
          INFORMATION SECURITY
            EPA's  information  security program has established  formal
      policy and guidance that recognizes that information is an Agency asset
      and that EPA is highly dependent on its information resources to carry
      out  its mission.  Under  these  policy  statements and manuals,
      information resources are  defined as automated information systems,
      computerized data bases, computer programs, collections of paper
      records, information on  microfiche  or microfilm, and computer
      installations.

            In determining responsibilities  for information security, EPA
      policy  relies  on a  framework  of  three primary roles: information
      owner,  user, and  custodian. The  owner of the information  is the
      individual  or organization who creates  and sponsors it.  Ownership
      involves authority and responsibility for the information, either in a
      programmatic or administrative  sense. The owner determines the
      sensitivity of the records and decides who will be allowed to use them.
      The users are individuals who are authorized by the owner  to access an
      application or a collection of information.  Cu&todians  possess ADP
      equipment or the  files housing paper records. The custodian is the
      individual(s)  responsible for the records  in the  property management
      sense.

            Regional records officers, as the custodians  of the regions'
      records, are responsible for  establishing procedures for securing the
      information resources.

            Objective

                 The objectives of a  regional  records security program are
            to maintain the availability of  general  management and
            program  records  while protecting their confidentiality and
            ensuring  their integrity by safeguarding them  from loss,
            alteration, or damage.

            Legal /Administrative Requirements

                 The listing  on the  following page highlights the major
            legal and administrative requirements for records  security with
            which the regional offices must comolv.
A^r t_ bk* V»* »^» fc*X* ** ***.*»v^fc» fc» V* V *.. • W^>| ***» W**»W*»fc^ J

which the regional offices must comply.
Model Regional Records Management Manual           (November 1991 draft)             145

-------
Records  Management Program  Components
                         LEGAt AND ADMINISTRATIVE REQUIREMENTS
                                   FOR RECORDS SECURITY
               EPA Information Security Manual
               Electronic Records Management:
               Final Rule
               Executive Order 12656:Assignment
               of Emergency Preparedness
               Responsibilities
                               EPA security policy and
                               procedures contained in this
                               document must be addressed
                               Strict procedures for
                               restricting access, as well as
                               preparing backup and recovery
                               mechanisms for electronic
                               records are required

                                Lead and support
                                responsibilities for protecting
                                EPA records in time of
                                emergency must be assigned
             For more detailed information on the requirements identified in
             each citation, the appropriate document should be consulted.

             Approaches

                   Key  issues in' implementing  the  policies of  EPA's
             information security program are:

                   •     Identifying and outlining responsibilities of those
                         records management professionals charged with
                         protecting records security

                   •     Determining the sensitivity of the records holdings

                   •     Identifying the primary threats to records
                         management information  systems

                   •     Developing procedures to address each of these
                         threats, balancing the need for integrity against the
                         requirements for access and confidentiality

                   •     Communicating established procedures to all
                         owners and users of records.
146
(November 1991 draft)
Model Regional Records Management Manual

-------
                                                          Information  Security
                        Managerial and  administrative roles -  Because
                  information  security covers  a  variety  of information
                  resources and  involves many different  employees and
                  supervisors,  it is important  to have one management
                  official  in each  program  and  administrative  division
                  coordinate the security for that division. The  regional
                  records  management programs should identify a records
                  management  liaison in each program who should assume
                  records  security  as  part of his/her  responsibilities. In
                  addition, the  Regional Records Management Coordinator
                  has overall responsibility  for maintaining the  records
                  (including related ADP equipment)  entrusted to the
                  records  center or centers. Therefore, the Regional Records
                  Management  Coordinator is charged  with enforcing
                  records  management procedures  that are designed to
                  protect  records from loss  or damage and  protect the
                  confidentiality of sensitive records. See following page.

                        Electronic  records  have  a  unique   set  of
                  requirements  for security, and  regions should designate a
                  person(s)  to  be responsible for  security  at the  region's
                  computer  processing installations (e.g.,  LAN  admin-
                  istrator;  mini-/mainframe administrator).   They approach
                  information  security both   from an  installation  or
                  equipment perspective and  from an application (or
                  system)  perspective.

                        Determining records sensitivity - Over the years,
                  EPA has developed several sets of procedures governing
                  specific  types  of sensitive information.   The great  majority
                  of these existing  procedures  deal with  some  type of
                  confidential information, especially confidential business
                  information (CBI). These procedures are  typically issued
                  by EPA organizations with statutory authority  for the
                  information (for  example,  the Office  of  Pesticides and
                  Toxic Substances for TSCA or FIFRA  CBI).  Owners of
                  regional records may refer to the documents listed in the
                  References section of this chapter  to review  existing
                  organizational  standards and procedures for sensitive
                  information that must be adhered to.
Model Regional Records Management Manual           (November 1991  draft)             147

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Records  Management  Program Components
                       INFORMATION SECURITY:  RESPONSIBILITIES BY ROLE
                    ROLE
                    IRM Branch Chief
                                  RESPONSIBILITIES

                               Implements the organization-wide
                               security program. Designates a
                               responsible person at each division.
                    Division Director (Record owner)  Determines information
                                                sensitivity. Assigns custody.
                                                Authorizes users.  Specifies backup
                                                and availability requirements.
                                                Makes sure users and custodian
                                                adhere to security requirements.
                    Regional Records Management
                    Coordinator
                    Records Officers
                               Specifics and approves security
                                controls. Establishes general
                               security procedures in consultation
                               with the records officers.

                               Enforces written security procedures
                               in daily operations. Trains records
                               center staff on security policy and
                               procedures.
                         The Sensitivity  Evaluation Table on the following
                   page is from EPA's Information Security Manual and may
                   be  used  as  a  worksheet for evaluating sensitivity of  a
                   particular record.  Following completion of this step,  the
                   owner may  wish to consult with his/her records officers
                   or  the  Regional Records  Management Coordinator  to
                   determine the relevant security objective (availability/
                   integrity/confidentiality)  and  sensitivity level (high or
                   medium) based on the type of information the collection
                   contains. Senior regional managers may choose to review
                   the sensitivity designations assigned to significant records
                   collections, as the implementation of  security safeguards
                   for these records  can involve  considerable expense and
                   investment of  staff time.

                         Threats to records security - Records are vulnerable
                   to threats to each of the three security objectives. Threats
                   to the availability of records  include theft,  accidental
                   destruction (e.g., flood, fire or human error) or deliberate
                   destruction by vandals or a disgruntled employee.
148
(November 1991 draft)
Model Regional Records Management Manual

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                                                             Information  Security
                          Sensitivity Evaluation Table
                      EPA Information Security Manual, 1989















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Model Regional Records Management Manual
(November 1991  draft)
149

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Records Management Program Components
                        Threats to integrity include accidental distortion
                  (particularly  with  electronic  records)  or  deliberate
                  distortion for  the purpose of revenge or to perpetrate or
                  cover up fraudulent activity.

                        Confidentiality of records may  be  threatened
                  through unauthorized  disclosure of stored  documents
                  (breakdown of security  in the records center or deliberate
                  unauthorized  sharing), or  carelessness in handling or
                  creating sensitive documents  (printer or copier  waste
                  paper not destroyed or disk copies of electronic records not
                  protected).  Procedures should be implemented  by the
                  regions to address each of these threats.

                        Procedures for maintaining records security - In
                  order to maintain the availability of regional records, the
                  records officers  should   store  the  records  (paper,
                  microform,  electronic or magnetic disk) in appropriate
                  storage equipment,  away  from potential  heat  or  water
                  damage. Sensitive records  should be stored in a fireproof
                  file  cabinet and  those in off-site storage  should  be
                  available within hours.  A document control and tracking
                  system must  be established  for  the  records center to
                  facilitate  retrieval  and prevent loss. In addition,  a
                  procedure must be established to enforce the access control
                  list (persons allowed access to the collection) established by
                  the owner of the records. (See  Section III.3 on Document
                  Control in this manual).

                        Procedures to  ensure integrity  must balance the
                  needs of availability against those of confidentiality.
                  Integrity involves elements of  the availability  objective
                  because if information is altered or partially destroyed, an
                  intact backup copy must be made available. On the other
                  hand,  integrity  involves elements of the  confidentiality
                  objective  because  preventing fraud and  sabotage are
                  largely problems of controlling  access. Protecting the
                  integrity  of the records involves adhering to all the
                  security procedures established  to control availability, and,
                  in addition, keeping sensitive  records in a  locked cabinet
                  or room whenever  the records are not in use.   Locks
                  should be changed  periodically or whenever there  is a
                  change in authorized users.
150             (November 1991 draft)           Model Regional Records Management Manual

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                                                          Information  Security
                        Preserving confidentiality involves controlling
                  access to records. Access controls for regional records are
                  generally of two types:  physical, such as door locks, and
                  administrative, such as lists that specify who may have
                  access to the records.  Strict policies on photocopying of
                  records should be established; photocopying by anyone
                  other  than  the  owner  of  the  records   is  generally
                  prohibited.   All confidential paper documents  must be
                  shredded or burned before being thrown away.  Discarded
                  microform should  be placed in burn bags for proper
                  disposal.  Magnetic disks  should be properly erased and
                  overwritten  before  being used again or  disposed  of.
                  The EPA Information  Security  Manual may  provide
                  additional  guidance  for  developing an  information
                  security program.

                        Communicating security measures to owners and
                  users -  It is important to the success of  the Regional
                  security program that the owners, users and  custodians of
                  the records  know and understand the security  measures
                  in place.  The regional records managers  may  assume
                  responsibility for  presenting  training sessions  and/or
                  distributing written material to staff at all levels on both
                  basic  information security and region-specific procedures
                  (See Section III.9, Staff Communication, in this manual).

            References

                  Guidance to assist  in the design  of  a records  security
            program can be found in several.existing documents, including:

                  •     EPA Information Security Manual

                  •     EPA Information Security Manual for  Personal
                        Computers

                  •     OPTS TSCA CBI Security Manual

                  •     OPTS FIFRA CBI Security Manual

                  •     OARM  National Security Information  Handbook

                  •     OSWER RCRA CBI  Procedures
Model Regional Records Management Manual           (November 1991 draft)             151

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Records Management  Program Components
                        OECM Enforcement Docket security procedures

                        OAR, OMS Procedures for Handling Auto
                        Manufacturers' Proprietary Data

                        AOR, OAQPS CBI procedures

                        Office of the Inspector General Manual

                        OW procedures for trade secret data

                        Executive Order 12656  on  Assignment of
                        Emergency  Preparedness  Responsibilities.
152             (November 1991 draft)            Model Regional Records Management Manual

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                                                               Public Access
      7.  ACCOMMODATING PUBLIC ACCESS
          REQUIREMENTS	

            The foundation for public access within EPA is the belief that an
      informed public is essential to meeting the Agency's mission to protect
      human  health and  the  environment and  to establish and enforce
      environmental regulations.  Therefore, the objective of public access in
      a global context is to make EPA's information available to the public in
      an cost effective, appropriate format, while meeting all applicable
      federal and EPA standards.

            Regional  managers should  view the records 'management
      program as a critical component of EPA's overall public access effort.
      For example, legislation increasingly requires,  and members of the
      public increasingly demand, direct access to many records maintained
      at the regional level, such as the Superfund Administrative Record,
      National Contingency Plan, and other records  contained in various
      media  program  or  administrative dockets.  Additionally,  regional
      libraries  and records  centers are  supporting growing  numbers of
      responses to  Freedom of Information Act (FOIA) requests, even though
      the primary responsibility for responding to the  FOLAs may  rest  with
      the Office of Public Affairs (or  the Information  Management Branch)
      and the relevant program or administrative  offices. Therefore, public
      access issues and how to address  them are important factors to be
      considered by the regional records management programs.

            Objective

                 The  public  access  objective of the  regional  records
            management program is to facilitate efficient EPA responses to
            requests from the public to review or obtain information.

           .Legal/'Administrative Requirements

                 The listing on the  following page  highlights the major
            legal and  administrative  requirements  for public access  with
            which  the regional  offices must comply.
Model Regional Records Management Manual           (November 1991 draft)             153

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Records  Management  Program  Components
                            LEGACANCTADMINISTRATIVE REQUIREMENT
                            Wl*   GOVERNING PUBLIC ACCESS
                  Freedom of Information Act (5
                  U.S.C. 552)
                  EPA Freedom of Information Act
                  Manual, 1986

                  Administrative Procedures Act
                  of 1966
                  Electronic Records Management:
                  Final Rule, 1990
                 Comprehensive Environmental
                 Response, Compensation, and
                 Liability Act
                 Final Guidance on Administrative
                 Records for Selection of CERCLA
                 Response Actions (OSWER Directive
                 #9833.3A-1)
                  EPA Contracting Policies (April
                  1990 Memorandum from The
                  Administrator)
                                 Requires Federal agencies to make
                                 records available to the public unless
                                 they meet one of nine exemptions
                                Outlines procedures for handling
                                FOIAs within EPA

                                Requires Federal agencies to make all
                                substantive rules and statements of
                                general policy available and to give
                                notice of proposed rulemaking so that
                                interested persons can participate
                                 Requires controls over classified.
                                 proprietary, and Privacy Act
                                 information stored electronically
                                Requires EPA to make administrative
                                records and proposed National
                                Contingency Plan records available to
                                the public


                                 Outlines procedures for public access
                                 to removal and remedial response
                                 actions, including those open to public
                                 inspection at a site
                                 Prohibits the actual preparation of
                                 FOIA responses, other than routine,
                                 non-judgmental correspondence by
                                 contractors and lists support by
                                 contractors in preparing FOIA
                                 responses as an activity of potential
                                 vulnerability
               For more detailed information on the requirements identified in
               each citation, the  appropriate document should be consulted.
154
(November  1991  draft)
Model Regional Records Management  Manual

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                                                                  Public Access
            Approaches

                  To meet the public access objective and the corresponding
            legal  and  administrative  requirements  identified  on  the
            previous page, Assistant Regional Administrators  and regional
            records managers must  be concerned with achieving two basic
            criteria:

                   •      Meeting the needs of the public to review or obtain
                         information within the context of the provisions of
                         relevant legislation, such as CERCLA, FOIA, and
                         other administrative  guidance.

                   •      Improving EPA's efficiency in locating  records
                         needed to respond to the public's requests for
                         information.

            To meet these  criteria,  the regional  records management
            program should:

                  •      Provide a public viewing room(s) to enable
                         members of the public to review records of interest

                  •      Promote efficient access to records by organizing
                         and maintaining the records in an appropriate
                         manner.

            Regional records centers will play a key role in the implementa-
            tion of each of these approaches.

                  To facilitate access while protecting the integrity of EPA's
            records,  the public viewing  area should  have the  following
            characteristics.  Specifically, the viewing area should:

                  •      Be secure to ensure that members of the public are
                         not able to access inappropriate information (e.g.,
                         Confidential Business Information, enforcement
                         sensitive information, or other files to  which they
                         have not been authorized access)

                  •      Be accessible to the public without allowing access
                         to other secure areas within the EPA facility
Model Regional Records Management Manual           (November 1991  draft)             155

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Records Management Program Components
                  •     Have a sufficient and appropriately trained staff to
                        assist the public and EPA program staff with their
                        requests, locate the relevant records, and monitor
                        use of the records to protect integrity

                  •     Use copies rather than originals where possible,
                        especially for frequently requested items

                  •     Have sufficient space to allow the public to review
                        records

                  •     Have available photocopying equipment or services
                        to allow the public, or program staff responding to
                        requests from the public, to make copies.

                  For records management programs  that handle large
            volumes of records and that receive extensive numbers of public
            requests to view these records, the program  may want  to
            consider making information that  is not  CBI or enforcement
            sensitive available to the public in  non-paper format, such  as
            microfilm, microfiche,  or  electronic.  If  microform  is  used,
            requestors could  use reader/printers to review the information
            and to make copies of relevant documents.  Use of microform
            offers benefits  to both EPA and the public as it facilitates access to
            the information by the requestor while protecting the integrity of
            the original records.  If public access to electronic information,
            such as a database, is allowed in the viewing room, precautions
            need  to be taken to  ensure that members  of the public  cannot
            access CBI,  enforcement sensitive,  or Privacy  Act information
            that is stored in the  database or alter or  otherwise  abuse the
            integrity of the electronic record.

                  Records management programs will  also need to develop
            operating procedures to support the public viewing room.  These
            procedures should cover topic-areas  such as:

                  •     Check in and check out

                  •     Duplication

                  •     Care of documents while in use by the public (i.e.,
                        instructions specifying that records should not be
                        written on or otherwise marked).
156            (November 1991 draft)           Model Regional Records Management Manual

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                                                                 Public Access
            For assistance in this area, regional records officers should refer
            to Section III.3, Document Control, of this document as well as to
            the operating procedures of EPA libraries, the FRC and regional
            archives.  Examples of forms used in various regional offices are
            included in the attachments at the end of this chapter.

                  The second approach to facilitating public  requests to
            information involves  improving EPA's ability to locate and
            retrieve records in which members of the public are interested.
            This  capability  is  particularly  important  with  regard  to
            improving responses  to  FOIA requests.  If the records  are
            organized  and maintained  so  that specific documents can  be
            easily located,  then this expedites preparation of the response.
            Records  management  staff  can further  assist the program  or
            administrative  staff by retrieving records for the staff member
            and by making copies of  specific records.  The ability to easily
            locate records also supports the functions of the public viewing
            room.

            Contractor Participation

                  Because  most of the  staff in the Regions involved with
            organizing and maintaining records are currently contractors,
            their involvement with FOIAs raises legal issues.  As stated in
            the  legal  and administrative  requirements  section,   the
            involvement of contractors in preparing responses to FOIAs is
            prohibited in all but cases  of routine correspondence, which does
            not involve judgment.  Any  contractor support in drafting FOIA
            responses is viewed as an activity of "potential vulnerability."
            Due to these constraints, it is most acceptable for contractors to be
            involved with  FOIAs only in terms of facilitating the retrieval
            and  duplication of the required records for the program  or
            administrative staff completing the FOIAs.

                  Existing  contracting policies do allow for some flexibility
            in  utilizing  contractor support  to  respond  to  routine
            correspondence requiring  no judgment.  For example,  it may  be
            appropriate for a contractor to retrieve a specified document
            requested through a FOIA,  while a request for all information
            relevant to contamination at  a Superfund site should be handled
            by the appropriate  Remedial Program Manager (RPM) or On-
            Scene Coordinator (OSC). However, once the RPM or OSC has
            identified the document to be used in the response, contractors
            can copy and assemble them. Allowing contractor staff to assist
Model Regional Records Management Manual           (November  1991 draft)             157

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Records  Management Program  Components
           with the preparation of responses for routine correspondence,
           not  involving  judgment,  may  help reduce  the  burden  on
           program or administrative staff.  The definition of  this type of
           FOLA would need to be standardized and reviewed by the Office
           of Regional Counsel.

           References

                 The  following documents  contain information  on public
           access  that may  be  useful  when  considering  how  to
           accommodate public access requirements into the Regional
           records management program.

                 •     EPA Freedom of Information Act Manual, 1986

                 •     Final Guidance on Administrative Records for
                       Selecting CERCLA Response Actions, 1990 (OSWER
                       Directive 9833.3A-1)

                 •     EPA's draft Public Access Policy (currently being
                       circulated for comment)

                 •     Memorandum  from  William  Reilly, "Contracting
                       at EPA," April 17,1990
153             (November 1991 draft)           Model Regional Records Management Manual

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                                                  . Public Access
                      ATTACHMENTS
                   Region VII Visitor Log




                   Request Form for Public Dockets




                   Public Docket Problem Report Form
Model Regional Records Management Manual         (November 1991 draft)          159

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Records  Management Program  Components
160             (November 1991 draft)            Model Regional Records Management Manual

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                                                                               Public  Access
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   Model Regional Records Management Manual
                                              (November 1991  draft)
161

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Records  Management  Program  Components
162              (November 1991 draft)           Model Regional Records Management Manual

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                                                                                  Public  Access
                             Request Form for Public Dockets
     Instructions:

     • Members of the public may request public docket records ooly. .

     • Publk Ar*-*y inxrdi do not circulzte. They may only be used in tbe Records Outer Public Reading Room.

     • Limited numbers of copies may be nude on the Records Center's copy machine.

     - Please complete all appropriate sections of the form.

     • Questions concerning (he use of public rtorlrit records may be directed to the Records Center Manager.
      1. Type of Public Docket (circle one):

          NPL Administrative Record         Federal Facility Docket

     2. Site Name:
                                                NPL Docket
     3. State (circle one):   CT
      MA
ME     NH
RI
VT
     4. Material to be
        Viewed
         Volume(s)
                 For Records Center Staff Use Only
Accession No.
                                   c:
       Given to
       Requestor
            Date & Time
             Returned
            by Requestor
                                                                                .c
    5. Name of Requestor

    6. Representing:	

    7. Address:
    8. Telephone Number
  EPA Refioo I (4/I4/U)
Model  Regional Records Management Manual
                          (November 1991 draft)
                                                163

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Records  Management  Program Components
164             (November 1991 draft)           Model Regional Records Management Manual

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                                                                                Public Access
                               Public Docket Problem Report
    Instructions:
     Have you experienced a problem wtuk asmf • poblk docket? Please provide as much information as pocsibte. This will
     allow the Region to comet (he problem in a timely manner. If you have any qoabom. pkate consult w«h the Saperfuod
     Records Center Manager.
    1.  Type of Public Docket (circle one):
         Administrative Record       Federal Facility Docket        NPL Docket
       Site/Facility Name:	
2.
3.
4.

5. State (circle one):    IA   KS   MO   NE
       CERCLISIDf (if known):
       Operable Unit	
       Name of Person Reporting Problem:

       Telephone*:	
                                                       8. Date:
   9. Type of Problem (select all that apply):

        Type of Problem  	      	
                                                               Major/Minor
                                                               Break
Index
Citation No.
   F]   Document listed in the Public Docket Index is missing from
        the Public Docket
        Document located in the Public Docket is illegible (e.g.,
        copy poorly reproduced).
        Document located in the Public Docket is damaged (e.g., torn;
        stained).
        Document in the Public Docket missing page(s).
        Page(s):   	
        Public Docket citation appears to be incorrect Give correct
        citation in Section 10.
        Other
   10: Additional Information on the Problem:
        (For example: document citation)
   For Supexfund Record* Center Staff Use Only
 EPA Rejio. VH (WW)
Model Regional Records Management  Manual
                                                   (November  1991  draft)
           765

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Records  Management  Program  Components
166    '         (November 1991 draft)            Model Regional Records Management Manual

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                                              Records Management  Technology
       8.  ELECTRONIC RECORDS MANAGEMENT
           TECHNOLOGY	

            Records management is one of the fundamental administrative
       activities performed at EPA in support  of ongoing mission-oriented
       operations.  All  types of  EPA  employees, whether  they  are
       administrative or  knowledge workers4, are involved with records
       management in  some capacity.  This involvement takes one of three
       forms - owner, user, or custodian - as discussed earlier. As the primary
       custodian  of most of  a  region's  records,  the  regional records
       management program has a unique opportunity to promote improved
       productivity of the region's records  owners and users by facilitating
       access  to EPA's records. Many steps have  already been taken  in  this
       direction due to the creation of records centers in most regional  offices.
       However,  the  application  of  appropriate technologies  to records
       management activities is key to improving access to information  and
       thus continuing to enhance worker  productivity.  Additionally,  the
       evaluation  and use of technological  applications to improve records
       management today will position regions  to take full advantage of the
       opportunities offered by technological advancements in the future.

            This  section  will discuss technology in records management
       through  presenting the basic objective of utilizing technology in
       records management, the legal and administrative  requirements,  the
       regional records officer's role in evaluating and  selecting technological
       applications, and information on  various  technological applications
       appropriate  for  use  in  the  records   management environment.
       Additionally, a scenario is offered  at the conclusion to this section to
      provide one idea of how records management will be conducted in a
       future  office environment.
      4 The "Technology Assessment and Technology Impact Reports" developed by
         Booz* Allen & Hamilton Inc. for the Comprehensive Analysis of Records and Forms
         Management Program in EPA Headquarters Offices Study define two types of
         workers - administrative and knowledge. Administrative workers perform and
         manage those  ongoing activities necessary to support the operations of the
         organization. The knowledge worker performs mission-related activities.


Model Regional Records Management Manual           (November 1991 draft)             167

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Records Management  Program  Components
            Objective

                  The objectives of technology in a records management
            system are to increase accessibility, improve cost effectiveness,
            and provide strict document control, in accordance with the
            needs and regulations of the Agency.

            Legal /Administrative Requirements

                  Specific legal and administrative requirements exist with
            respect to the application of technology in records management.
            A listing of these requirements is presented in the graphic on the
            following page.
168             (November 1991 draft)           Model Regional Records Management Manual

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                                                            Records  Management  Technology
                              LEGAL AND ADMINISTRATIVE REQUIREMENTS--—
                               FOR RECORDS MANAGEMENT TECHNOLOGY
                    General Federal Guidelines at 44 U. S. C.
                    3101-07. 41 CFR 101
                    NARA Regulations at 36 CFR Part 1234
                    NARA Regulations at 36 CFR Part 1230
                    NARA Bulletin 91:2: Use of Optical Disc
                    Systems to Store Permanent Federal
                    Records

                    NARA Regulations at 365 CFR 123.183
                    Privacy Act of 1974 at 5 U.S.C. S52a
                   Paperwork Reduction Act of 1980
                   Electronic Communications Privacy Act
                   (P.L 99-508)
                   National Security Decision Directive
                   (NSDD) 145. September 17. 1984
                   EPA's Records Management Manual
                   EPA Information Security Manual
                   (December 1989)
                   Implementation of Image Processing
                   Systems (OIRM Policy Directive)
 Electronic records must follow NARA
 and Agency guidelines for the
 security and disposition of records,
 including destruction and transfer to
 a Federal Records Center

 Regulations establish standards for
 the use of micrographic technology
 with federal records

 Agency may not transfer records
 stored on optical disc to NARA
Agency must conform to standards
when transferring machine readable
records to National Archives

Agency will acquire and operate
information technology in an
effective and economical manner

All records management functions,
including electronic recordkeeping,
should be consolidated in a single
agency official

Agency must provide safeguards for
access to electronically transmitted
information

Agency must meet minimum security
requirements for civilian Federal
agencies for maintaining sensitive
data on computer systems

Manual contains information on how
to justify the need for micrographics
systems within the Agency

Manual explains how to comply with
electronic security requirements
outlined in the 1987 Information
Security Policy

Policy establishes the principles for
the acquisition and use of image
processing systems
Model Regional Records Management  Manual
 (November 1991  draft)
169

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Records Management Program Components
            Approaches

                  This section covers two main areas:

                  •     A framework that records officers can utilize to
                        evaluate and select appropriate technologies for use
                        in records management

                  •     A discussion of the capabilities, advantages, and
                        disadvantages of the currently available
                        technologies.

                  These are each discussed in turn.

                  Evaluation Framework

                  A  critical  first  step   in  evaluating   and  selecting
            technological applications for use in  records  management is an
            assessment of the effectiveness of current records management
            policies, procedures, operations, and personnel.5  If the current
            records management  program  is  outdated,  ineffective, or
            unresponsive  to the  region's  needs,  the  application of
            technology will  not  solve  these  problems.  Therefore, the
            regional  records  manager should lead an assessment of the
            current records management environment  before  embarking
            upon additional  assessment  of technological solutions.  This
            assessment can be conducted through  use of the following
            framework:

                  •     Define Organizational Mission - The records officer
                        should first define the goals, objectives, and
                        functions of the organization that the records
                        management program supports in the  context  of
                        EPA's overall goals and priorities.
                        Accomplishment of this  task will necessitate
                        evaluation of mission statements, relevant laws,
                        regulations, and administrative policies,
                        organizational goals, and human resources
                        management issues. This definition establishes a
                        framework for identifying document management
                        needs.
         Much of the information contained in this section is paraphrased from the Guidance
         for Developing Image Processing Systems in EPA, February 1991.  This document
         should be referenced for more detailed information.
170             (November 1991 draft)           Model Regional Records Management Manual

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                                               Records Management  Technology
                         Describe Current Document Management System -
                         The records officer needs to evaluate the current
                         records management system so as to obtain an
                         overall description of the life cycle of documents
                         critical to the operations and performance of the
                         office.  This evaluation requires identifying the set
                         of records needed to support the office's functions
                         and then differentiating these documents by how
                         they are created and how they are used.  For
                         example, the records could be categorized as forms,
                         reference materials, working and official
                         documents, or archival materials.  The next
                         component of this task is to develop an overall
                         description of the records management system,
                         including identification of strengths and
                         weaknesses.

                         Define Document Management Problems - The
                         records officer next needs to dearly define
                         document management problems so as to identify
                         the region's needs in this area and potential
                         technological solutions.  These problems can be
                         either unmet records management needs or
                         deficiencies in the existing system relative to the
                         organizational mission.  Additionally, the records
                         officer must consider the resulting implications  for
                         the region of correcting these problems.

                         Identify Document Management Needs - The
                         previous two tasks provide the framework for
                         identifying the required capabilities of an improved
                         records management system. The new system
                         should preserve existing strengths, correct system
                         weaknesses, and eliminate deficiencies.  The
                         regional records manager can utilize five criteria to
                        establish a basis for evaluating alternative
                         technologies relative to records management needs:

                              Document Access - Frequency, speed, single
                              user or multi-user, and other access
                              characteristics

                              Document  Storage - Storage quantity,
                              duration, and mandate (e.g., how long must
Model Regional Records Management Manual           (November 1991 draft)             171

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Records Management  Program  Components
                             documents legally be retained) as well as
                             requirements for  active or inactive
                             documents

                             Document  Distribution - Extent of internal
                             and external distribution and type of
                             distribution

                             Document  Control - Security requirements,
                             document accountability, and security for
                             portions of documents or for data from
                             documents

                             Document  Processing - Single or multiple
                             persons processing documents and internal
                             and external document processing.

                  •      Identify Possible Solution Areas - In this step, the
                        records officer identifies technological solution
                        options that meet the previously defined
                        requirements. These potential solutions may
                        include:

                             Improved paper-based systems

                             Microform systems  using microfilm or
                             microfiche

                             Image Processing Systems

                             Hybrid combinations composed of the above
                             categories and other Management
                             Information Systems technologies.

                  After this mission-needs assessment has been completed,
            the records  officer should  conduct  a feasibility study  to
            determine if the proposed solution  can  be  justified within the
            context of existing constraints. Completion of this type of study
            requires  development of an operational cost baseline of the
            existing system so that it can be compared to proposed solutions,
            further refinement  of the alternatives,  development of cost
            estimates for the alternatives,  and consideration of other factors,
            such as technological  and organizational issues and additional
172             (November 1991 draft)           Model Regional Records Management Manual

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                                               Records  Management  Technology
             mission needs unmet  by  the  current records  management
             approach.6

                   Available Technologies

                   The following  text provides an overview of  available
             technological  applications  through presenting  descriptions,
             advantages,  and disadvantages  of  various  technological
             solutions  which  should  be  considered  for  use  in  records
             management.

                   •     Paper - Paper is currently the most common form
                         of information storage and has established the
                         standard  for convenience, cost, and functionality
                         with  regard to information transfer.  The physical
                         characteristics of paper include a diverse range of
                         sizes, colors, thicknesses, and compositions. These
                         physical characteristics can convey a message
                         beyond that communicated by the actual
                         information which is stored. The expected lifetime
                         of paper depends upon the type used and the
                         environmental conditions in which it is  stored;  this
                         lifetime can range  from  a few days to hundreds of
                         years. Paper storage techniques are based upon the
                         physical filing of document and involve  a trade-off
                         between file integrity and access (i.e., tightly
                         controlled documents must  have restricted access
                         and thus are usually stored in a centralized location
                         whereas documents requiring significant access are
                         often copied and stored in decentralized  locations).
                         Several techniques have been developed to
                         improve the effectiveness of storage and retrieval
                         and to reduce  paper storage volumes.

                              Movable filing systems using mechanical
                              and electrical features to reduce the amount
                              of access space required between filing
                              cabinets and shelves.  These types, of filing
                              systems allow documents to be stored at
                              much higher storage densities than standard
                              paper-based systems.
      ^  One approach to completing a feasibility study is discussed in detail in Chapter III
         of the Guidance for Developing Image Processing Systems in EPA.


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Records  Management  Program  Components
                               Computer-based indexing systems that
                               identify the storage location and control the
                               distribution of paper documents. The
                               location and description of each document
                            •   can be entered into the system along with
                               tracking information.

                         Regardless of how the documents are stored, once
                         the volume exceeds available space, obsolete or
                         seldom-needed documents must be retired to a
                         remote location or destroyed. The following
                         graphic summarizes the advantages  and
                         disadvantages of paper.
                           Advantages

                           Standard media for
                           information transfer

                           Admissible as legal
                           evidence

                           Any display format
                           and size is possible
                           Easy to reproduce
                           information

                           Easy to update
                           information

                           Easy to manually
                           browse documents
                                  Disadvantages

                                  Large storage space
                                  required

                                  Retrieval time may be
                                  slow

                                  Large volumes can be
                                  difficult to manage and
                                  expensive to move

                                  Easy to loso or damage
                                  documents

                                  Changes may be difficult
                                  to identify and track

                                  Limitted to a single
                                  arrangement scheme which
                                  may or may  not meet research
                                  needs.
                         Micrographics - Micrographics involves a
                         photographic process in which the image of a
                         document is transferred by camera onto unexposed
                         film.  The film is then subsequently exposed,
                         developed chemically or by heat, and stored in one
                         of the following forms:

                               Microfilm Rolls  - Documents are
                               sequentially photographed on a film roll
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                                               Records  Management  Technology
                               either 100 or 215 feet long using either 16
                               mm or 35 mm film. A 100 foot roll of 16 mm
                               film contains approximately 2,400 images of 8
                               1/2" X 11" pages. These rolls are stored in
                               open reels or enclosed cartridges.

                               Microfiche - Microfiche stores photographic
                               images of documents in a grid format on a
                               small rectangular piece of film.  Each
                               microfiche has dimensions of 4" X 6" and
                               usually contains up to 98 images which can
                               be stored at a density of approximately 120
                               sheets per inch.

                               Jacketed Microfilm - Jacketed  microfilm
                               combines microfilm roll and  microfiche
                               storage techniques.  After cutting standard
                               roll film to the appropriate length (based on
                               the width of the jacket), it is then inserted
                               into clear plastic jackets containing channels
                               for film. The images are initially developed
                               on microfilm rolls and then stored in rows
                               similar to microfiche.  This format is easily
                               updated by adding or removing slides.
                                                      *»
                               Aperture Cards - Aperture cards use a
                               standard computer punch card to store a
                               piece of 35 mm film. The film is mounted in
                               a window, and information is then encoded
                               on the card so that the image can be sorted
                               and retrieved.  Usually one image is stored
                               per card although multiple images can be
                               stored.  These cards are frequently used for
                               engineering applications, including
                               architectural drawings, geographical maps,
                               and charts.  Due to the outdated punch card
                               technology, aperture card applications are
                               currently being replaced with  microfiche-
                               sized aperture cards that allow combined
                               storage of large format 35 mm images and
                               normal-sized document images.

                        The storage density of micrographics is usually
                        quite high, but special filming, processing, reading,
                        and printing equipment are required.  Although
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Records Management Program Components
                       the filming and processing operations can be
                       performed by a service bureau, viewing and
                       printing equipment will need to be purchased. The
                       optical viewing equipment is available with
                       various capabilities, including differing
                       magnifications, screen sizes, and image retrieval
                       abilities.  Micrographics printers allow a user to
                       produce a paper copy of the image on demand.
                       Additionally, various micrographic systems exist
                       that combine micrographies' high storage densities
                       with the capabilities of a computer. These systems,
                       which are discussed below, offer substantial
                       improvements for storing and accessing
                       documents.

                             Computer-Aided Retrieval (CAR) - CAR
                             systems are most useful for storing archived
                             documents that require infrequent retrieval.
                             Documents are photographed  on microfilm
                             and descriptive information is entered for
                             each document in a computer data base. A
                             frame number or an image mark is encoded
                             next  to each image on the film. The database
                             retains this number or mark and associates it
                             with the document description. To retrieve a
                             document, the descriptive information is
                             entered and the computer directs the image
                             reader to manipulate the film and retrieve
                             the image associated with the document.
                             Microfilm supported by CAR systems can be
                             used to transition to an optical disk system as
                             film based images can be scanned, converted
                             to a digital format, and transmitted to an
                             optical disk system. The film index is
                             accessed through the image processing
                             system.
                                        s
                             Computer Output to Microfilm (COM) -
                             COM systems print computer-generated data
                             and scanned images directly onto film, thus
                             bypassing the need to produce a paper copy of
                             the data. This system is especially
                             appropriate when large amounts of
                             computer data or images stored on magnetic
                             or optical media" need to be permanently
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                                                Records Management  Technology
                               archived.  The storage space on the magnetic
                               media can be reused.

                               Digitized Microfilm - These systems,
                               sometimes referred to as automated
                               document storage and retrieval systems
                               (ADSTAR) or videomicrographics systems,
                               convert document images stored on film to
                               digital data and then process them by
                               computer. Film rolls are automatically
                               retrieved and the selected images are located.
                               The image is then converted, via a scanner,
                               to a digital format where a computer
                               electronically processes and sends the
                               document to another computer or a printer.

                         The following graphic summarizes the basic
                         advantages and disadvantages of micrographics.
                            Advantages

                            High storage capacity

                            Admissible as legal
                            evidence

                            Well proven and tested
                            technology

                            Easy and cost effective
                            to duplicate

                            Most document formats
                            can be displayed

                            Low conversion costs
   Disadvantages

   Retrieval time may be slow

   Film may be difficult
   and expensive to update

   Film can be easily lost
   or damaged

   Document browsing may
   be time consuming
                        Image Processing Systems - Image processing
                        systems convert images to a digital format that can
                        be manipulated by a computer.  When an image is
                        recorded using digital processes, it is scanned and
                        transformed into binary digits - ones and zeroes.
                        The digital format is then viewed on a computer
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Records Management Program Components
                        terminal, printed, stored, or transmitted to other
                        users.  However, electronic digitized images only
                        record a limited degree of detail. Virtually any
                        media that can store digital information can be used
                        to store digitized images, including the following:

                              Magnetic Storage - With magnetic storage
                              media, the digital values that comprise text
                              and image information are recorded as a
                              sequence of electrical charges on a
                              magnetically-coated surface, such as magnetic
                              tape, disks, and cards. There are wide
                              variations in data storage capacities and
                              access speeds of magnetic media.

                               ••    Magnetic Tape - Information stored on
                                    magnetic tape must be accessed
                                    sequentially resulting in slow access
                                    time.  Storage capacities for magnetic
                                    tape range from 5 to 10 megabytes of
                                    data on a 100 foot length of tape. This
                                    media is best suited for systems with a
                                    large volume of transaction processing
                                    (due to the high storage capacity and
                                    low cost) and little to  no need for
                                    random data access.

                               ••    Magnetic Disks - Information stored
                                    on magnetic disks  can be retrieved
                                    quickly (usually within a fraction of a
                                    second) due to the high speed,
                                    continuous rotation of the disks.
                                    However, in comparison to magnetic
                                    tape, the storage capacity is limited.
                                    Magnetic disks can be either hard disks
                                    with high storage capacities or floppy
                                    disks which are portable storage
                                    media. Storage capacity for floppy
                                    disks ranges from 720 to over 1,400
                                    kilobytes of data.  Hard disks for
                                    personal computers hold from 20 to
                                    over 200 megabytes while hard disks
                                    for mini and mainframe computers
                                    range from 500 megabytes to over 2
                                    gigabytes of data per disk.
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                                               Records  Management  Technology
                              Optical Storage - Optical storage media
                              contain digital values that compose text and
                              image information recorded by a laser light
                              as a series of holes or bubbles on a reflective
                              disk surface. The disk can be read by
                              reflecting laser light from the recorded
                              information through a detector back into a
                              computer.  Optical storage devices come in
                              various forms.

                              ••    Compact Disk/Read Only Memory
                                    (CD/ROM) - CD/ROMs contain
                                    prerecorded text or image information
                                    that can only be read, not altered.
                                    After a CD/ROM has been stamped
                                    with information from the master
                                    disk, no information can be changed
                                    or added. This type of optical storage is
                                    commonly used as  a publishing
                                    medium.

                              ••    Write Once Read Many (WORM) -
                                    WORM disks allow the user to record
                                    information one  time  and then
                                    subsequently  read  this information
                                    repeatedly.  These disks hold from 1 to
                                    6 gigabytes of data per disk.  WORM
                                    disks provide a secure storage medium
                                    that cannot be altered, thus making
                                    these disks useful for long-term
                                    storage or for highly sensitive
                                    documents.

                              • •    Erasable Optical Disk - Information can
                                    be repeatedly written to and erased
                                    from this storage medium. Erasable
                                    optical disks generally store from 1 to 4
                                    gigabytes of data/disk. These disks are
                                    very  useful when storage
                                    requirements are high, and
                                    information must be repeatedly
                                    updated.
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Records Management Program Components
                        Image processing systems can be assembled so that
                        they perform one of three types of functions.
                                         Retrieval Systems—Documents"
                              are scanned and stored on an optical disk
                              (WORM or erasable) and then displayed on a
                              monitor, reprinted, transmitted to another
                              location, or copied to another disk.  After
                              scanning,  paper documents are either stored
                              locally, archived at a remote location, or
                              destroyed. Storage and retrieval systems
                              offer many benefits:

                              ••    Documents can be stored at a higher
                                    density

                              • •    Documents can be securely stored

                              ••    Documents can be retrieved rapidly

                              • •    Documents can be filed using a cross-
                                    indexing method

                              • •    Documents are always available for
                                    use

                              While these benefits can lead to increased
                              productivity and efficiency, they must be
                              weighed against higher equipment and
                              startup costs and the as of yet unresolved
                              issue of legal admissibility for optical media.

                              Long Term Storage Systems - These systems
                              are used primarily for the long term storage
                              of documents requiring infrequent access.
                              Documents are scanned on optical media
                              (WORM or erasable) at a very high storage
                              capacity as the primary objective is to
                              maximize storage density with limited
                              consideration  of access and retrieval time.
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                                               Records  Management  Technology
                               Document Processing Systems - Document
                               processing systems allow information to be
                               added, validated, or extracted from a
                               document as it passes through the various
                               stages of processing.  Instead of manually
                               processing a paper document, an electronic
                               form of the document is automatically
                               passed from one station to the next.  This
                               capability simplifies and accelerates
                               document processing activities, such as
                               review and approval  cycles.  Document
                               processing offers many of the same
                               advantages  as those listed for storage and
                               retrieval systems as well as offering
                               additional benefits resulting from the
                               networking capabilities.  These benefits
                               include:  electronic document transmission,
                               distribution, pacing, sequencing, prioritizing,
                               tracking of  comments, and integration with
                               other systems.  Software development and
                               maintenance costs are usually higher for
                               these systems than for storage and retrieval
                               systems.  Those processes which are highly
                               procedural, time sensitive, or have
                               mandatory processing cycles are most
                               appropriate for this type of system. The
                               following graphic  summarizes  the
                               advantages and disadvantages of image
                               processing systems.
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Records  Management Program  Components
                            Advantages

                            High storage capacity

                            Rapid access to
                            documents

                            Easy to reproduce
                            information onto paper

                            Difficult to misplace or
                            damage documents

                            Document security and
                            integrity is enhanced

                            Single documents can be
                            simultaneously viewed

                            System can be easily
                            expanded

                            System can be integrated
                            with other
                            technologies/systems
                                   Disadvantages

                                   High equipment costs

                                   High document conversion
                                   time and costs

                                   Environmentally-controlled
                                   room may be required

                                   High maintenance and
                                   support costs

                                   Inability to access documents
                                   during system downtime

                                   No decision on legal
                                   admissibility
                         Hybrid Image Processing Systems - Hybrid image
                         processing systems employ many different
                         technologies to maximize performance, efficiency,
                         and cost effectiveness.  A hybrid  solution may
                         incorporate multiple storage techniques, such as
                         paper-based, micrographics, and imaging, as well as
                         other complementary information technologies,
                         such as bar coding, text processing, optical character
                         recognition (OCR), electronic data interchange
                         (EDI), electronic forms, network architectures,
                         facsimile transmission, and  electronic and voice
                         mail. Hybrid systems may be appropriate where the
                         requirements are large, diverse, and complex.
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                                                       Records  Management  Technology
               Office of  the Future  Scenario
                      In  the future office environment, each employee will have a single
               workstation at his/her desk connected to other workstations via local area
               networks as well as to the national network as needed.7 The workstation will
               be integrated with the voice communication system to provide enhanced
               integration between data, voice, and image.  However, due to cost constraints
               and limited requirements to perform certain functions, not all workstations will
               have all capabilities.  Instead, strategically located  areas will  provide
               specialized technology capabilities.

                      In  a future office environment,  such as this, records  management will
               operate in a  different manner lhan it  is currently.  The following  scenarios
               provide examples of how the records management function might be completed
               in this future office environment.

                      An EPA employee in a program office wants to determine the status of
               his/her outstanding travel vouchers.  The employee queries the computer and
               learns that the previously submitted voucher has not been  approved due to
               inconsistencies between the information recorded on the form and the receipts
               attached.  As  this employee does not have access to image at his/her desk,
               he/she calls the Finance Office to resolve the problem.  The employee in the
               Finance Office retrieves the voucher in one window and the image of a scanned
               dinner receipt in another. By comparing the two, the Finance employee is able
               to discover, communicate, and, based upon the oflier employee's input, correct
               the discrepancy.

                     The program office employee  is then working on  responding to  a
               Freedom of Information Act (FOIA) request which  has been electronically
               routed to him/her through  the controlled correspondence system.  In order to
               respond to  this FOIA, the employee needs to locate and examine relevant public
               comments received in reference to a specific regulation. The employee calls up
               an index to all the public comments and other information maintained in the
               records center, electronically searches for the appropriate comments, and upon
               locating the relevant comments, notes their location (i.e., appropriate records
               center).   As the comments of interest  are listed as  being available through
               another program office's records center, the employee walks  to the center and
               utilizes its  workstation to pull up the image of the comments in which  he/she
               is interested.  The employee prints a copy of the image and returns to his/her
               office to complete the FOIA response.
           The information contained in this section is based upon the scenarios presented in
           The "Technology  Assessment and Technology Impact  Reports"  developed by
           Booz* Allen & Hamilton Inc. for the Comprehensive Analysis of Records and Forms
           Management Program in EPA Headquarters Offices Study.
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Records  Management Program  Components
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                                                       Staff Communication
      9.  REGIONAL STAFF COMMUNICATION	

            In order  to contribute to  the  operation of  the  records
      management program, regional  staff must first understand the
      objectives,  legal/administrative requirements, and functions of the
      regional records  management program.  As creators  and users of
      regional records, program and general management staff contribute to
      the regional records management program throughout the life cycle of
      the record.  These staff:

            •     Create records to be inventoried and managed by the
                  regional records management program

            •     Maintain records and provide insight to records
                  management staff regarding user needs, such as access

            •     Help determine how to manage inactive records through
                  disposition or storage.

      The Regional Records Management Coordinator must take the lead in
      communicating regional records management policies to ensure that
      staff activities are conducted  in a  manner that is consistent  with
      national and regional records management program objectives.  Two-
      way communications between records management program staff and
      program and general management  personnel will lead  to a broader
      understanding of the Agency's role and responsibilities as custodian of
      public  information.

            Objective

                  The overall objective for providing records management
            information and  resources  to   regional  staff  is  to  utilize
            teamwork and  information  sharing  to  attain  national and
            regional records management  program objectives.

                  In order to attain the goal of acting as a resource in  records
            management  policies and  procedures, the regional program
            must  be active  in  communicating  records  management
            principles,  accessible  in assisting staff in integrating these
            principles, and understanding of staff needs.
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Records Management Program  Components
            Legal/Administrative  Requirements

                  The  list below highlights  the major legal/administrative
            requirements for regional communications regarding the records
            management program.
                       LEGAL AND ADMINISTRATIVE REQUIREMENTS
                          FOR REGIONAL STAFF COMMUNICATION
                IRM Strategic Plan
                1991-1995
                   Establishes IRM program commitments to:

                   •  Increase end user knowledge through teamwork
                     and information sharing

                   -  Ensure effective and appropriate handling of
                     Agency records through realistic guidelines for
                     records management

                   -  Provide technical assistance and client support to
                     facilitate efficient use of IRM resources
            Approach

                  The  design  of  the  region's  records  management
            communication strategy should consider:

                  •     Information needs of records users

                  •     Selection of appropriate communication vehicles

                  •     Frequency of regional communications.

            Consideration of these variables will  help  the regional records
            management  program  expand  communication,  leading  to
            increased mangement efficiency and  productivity for regional
            staff.

                  Information needs of records users - Under the leadership
            of the Regional Records  Management Coordinator, the regional
            records   officers   should   take  the  lead   in   designing
            communications  objectives for regional record  users.  These
            objectives should incorporate the needs of regional staff and
           .other record users, including headquarters and the public. The
            region's information needs can be assessed through discussions
            with records management staff and program managers regarding
            issues or problems,  or direct  observations regarding the use of
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                                                         Staff  Communication
            records management resources.  For example, under-utilization
            or misuse of regional records management forms  or  tracking
            system  may indicate  a lack of user understanding of records
            management program  objectives or the inability to  incorporate
            records  management procedures  into program  operations.
            Through communication with regional staff, the records officers
            can  pinpoint  areas where additional training, information-
            sharing, or, where possible,  revised records  management
            procedures may be appropriate. The choice of commmunication
            tools and the  overall information strategy will  depend  on an
            accurate and timely assessment of the intended audience.

                  In assessing the information  or communication needs of
            regional staff,  the  regional records management staff should
            consider the broad range of records needs facing regional records
            creators and users.   Specifically,  the records officers must
            consider the needs of a particular program or management office
            in order  to  best  assist  the  staff  in  incorporating  records
            management   into  everyday  practice.  In  addition,  the
            information needs of an  infrequent record user, such as a
            member of a  Superfund  site community,  also  need  to  be
            addressed. These needs will  change  as the region's records
            management program  evolves; therefore, continued reviews of
            the region's user population will be important to an effective
            communication strategy.

                  Selection of appropriate communication vehicles - After
            the target audience has been identified, the  region should select
            appropriate  communication vehicles. There  are  various
            outreach tools to be considered such as:

                  •     Formal communications in the  form of briefings
                        lectures, and training classes

                  •     Informal communications in the form of group
                        discussions, such as staff meetings, where the
                        region's records management staff can share
                        information in a relaxed and interactive
                        environment

                  •     Written information  (posters, instructions, fact
                        sheets) either posted or  distributed through
                        established channels, such as a regional newsletter
                        or  orientation packets
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Records Management  Program  Components
                  •     Written and audio-visual materials that encourage
                        regional staff to familiarize themselves with
                        records management procedures and polices

                  •     On-line instruction through a LAN application
                        whereby staff can access records management
                        information and instructions.

            There  is a  broad  range of  records  management program
            literature available  through  professional associations, and
            Agency-specific information can be obtained through the NRMP
            staff. Specific resources are provided in the attachment to this
            document. Where region-specific  training  tools are warranted,
            the  Regional Records  Management Coordinator may choose to
            obtain contractor assistance or  other technical support to design
            appropriate information exchange  tools.

                  Frequency of regional communications - Finally, regions
            must decide on the frequency of communications.  The Regional
            Records  Management Coordinator must work with  records
            officers and  their regional  manager to identify communications
            needs on an ongoing  basis and develop steps to address those
            needs.  Depending on  the topic and audience, regions may use
            NRMP  materials  and  personnel or share new  materials
            developed by resources organizations and other regions.  A list of
            resource organizations is provided on the next page.
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                                                                         Staff  Communication
                 Information Resources for Records Management
                           Materials/Communication Tools
        Administrative Management Society
          AMA Building
          2360 Maryland Road
          Willow Grove, PA 19090

        American Federation of Information
          Processing Societies, Inc.
          1815 North Lynn St., Suite 800
          Arlington, VA 22209

        American Library Association
         110 Maryland Avenue, NE
         Washington, DC 20002

        American Management Association
          135 West 50th Street
          New York, NY 10020

        Association  for Information and Image
          Managers
          8728 Colesville Road
          Silver Spring, MD 20910

        Association  for Systems Management
          24587 Bagley Road
          Cleveland, OH 44138

        Association of Information Processing
          Professionals
          1015 North York Road
          Willow Grove, PA 19090

        Association of Records Managers and
          Administrators, Inc.
          4200 Somerset
          Suiet 215
          Prairie Village, KS 66209

        Data Processing Management  Association
          505 Bussc  Highway
          Park Ridge, IL 60068

        Financial Executives Institute
          Ten Madison Avenue, #1938
          Morristown, NJ 07960

        Institute  of Certified Records Managers
          P. O. Box 8188
          Prairie Village, KS 66208

        International Information Management
          Congress (IMC)
          P. O. Box 34404  •
          Bethesda,  MD  20817
International Records Management Council
  22243 Miston Drive
  Woodland Hills, CA 91364

National Association of Government Archives
  and Records Administrators (NAGARA)
  New York State Archives
  Cultural Education Center
  Albany, NY 12230

National Association of Small Business
  Investment  Companies
  1156 15th Street NW, S1101
  Washington, DC  20005

National Business  Forms Association
  433 East Monroe Avenue
  Alexandria, VA 22301

National Micrographics  Associations
  8719 Colesville Road,
  Silver Spring, MD  20910

National Office Products Association
  301 N. Fairfax Street
  Alexandria, VA 22314

National Records Management Council
  60 East 42nd Street
  New York, NY 10065

Office Automation Management Association
  440 Main Street, Suite 127
  Ridgefield, CT 06877

Society for the Advancement of Management
  2331 Victory Parkway
  Cincinnati, OH 45206

Society for Information Management Systems
  One Illinois Center
  111 East Wacker Drive, Suite 600
  Chicago, IL  60601

Society of American Archivists
  600 S. Federal, Suite 504
  Chicago, IL  60605

Special Libraries Association
  235 Park Avenue South
  New York, NY 10003
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        (November 1991 draft)
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   APPENDIX A
Inventory of Records Management Studies
for EPA

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                             Appendix A
            Inventory of Records Management Studies for EPA

The following is a list of recent studies supporting improvements in EPA's
records management program.  The studies are presented in chronological
order.

1.     U.S. Environmental Protection Agency, Region I. Development of
      Improved Procedures for Records  Management for Region I Superfund
      Program prepared by American Management Systems, Inc. 17 October
      1986.

2.     U.S. Environmental Protection Agency, REM HI Program Guidelines -
      Program Filing System prepared by EBASCO Services Incorporated.  12
      August 1987.

3.     U.S. Environmental Protection Agency. Region III. File System
      Maintenance Procedures: CERCLA File Organization Project prepared
      by Booz, Allen & Hamilton, Inc. October  1987.

4.     U.S. Environmental Protection Agency, Region IV.  Development of
      Improved Procedures for Records  Management for the Region IV
      Superfund Program - Task 2.3:  Superfund Improvement Options
      prepared by American Management Systems, Inc. 8 June 1988.

5.     U.S. Environmental Protection Agency. Region in. RCRA File System
      Report prepared by Booz, Allen &  Hamilton, Inc. September 1988.

6.     U.S. Environmental Protection Agency. Office of Administration and
      Resources Management.  Evaluation and  Design  of a Microform
      System for the Procurement and Contract Management Division
      prepared by Booz, Allen & Hamilton, Inc. June .1988.

7.     U.S. Environmental Protection Agency, Region I.  Development of
      Removal Program Site File Structure for Region I Environmental
      Services Division prepared by American Management Systems, Inc.  18
      July 1988.

8.     U.S. Environmental Protection Agency, Region I. Briefing on the Draft
      Superfund Removal Program  Site  File  Structure for Region I
      Environmental  Services Division,  U.S. EPA  prepared by American
      Management Systems Inc. 29 July 1988.

9.     U.S. Environmental Protection Agency, Region IV.  Development of
      Improved Procedures for Records  Management in EPA Region IV

-------
      Superfund Program - Task 2.1: Requirements Analysis prepared by
      American Management Systems, Inc. 2 December 1988

10.    U.S. Environmental Protection Agency.  Region in.  Data Base
      Documentation for the Region III Administrative Record File Indexing
      Data Base prepared by Booz, Allen & Hamilton, Inc.  January 1989.

11.    U.S. Environmental Protection Agency, Removal Site Records
      Management Manual  Draft prepared by American Management
      Systems, Inc. 8 March 1989

12.    U.S. Environmental Protection Agency, Region IV.  Overview of
      Region V Superfund NPL Site File Organization and Administrative
      Record Compilation prepared by-American Management Systems, Inc.
      20 March 1989.

13.    U.S. Environmental Protection Agency, Region IV.  File Structure
      Guidance for Region IV Superfund NPL Site Files and Superfund
      Removal Site Files Version 1.2 prepared by American Management
      Systems, Inc. 24 March 1989.

14.    U.S. Environmental Protection Agency.  Region III.  Data Base
      Documentation for the Region in Administrative Record File Indexing
      Data Base prepared by Booz, Allen & Hamilton, Inc.  January 1989.

15.    U.S. Environmental Protection Agency. Region III.  Administrative^
      Record File Procedures for Removal and Remedial Sites Under
      CERCLA prepared by Booz, Allen & Hamilton, Inc.  March 1989.

16.    U.S. Environmental Protection Agency, Region IV.  Waste
      Management Division. Superfund  Records Center Operations Manual
      prepared by American Management Systems, Inc. May 1989

17.    U.S. Environmental Protection Agency, Office of Pesticides and Toxic
      Substances. Procurement Analysis  for  a Document Storage and
      Retrieval System prepared by Booz, Allen & Hamilton, Inc. June 1989.

18.    U.S. Environmental Protection Agency, Region I.  Waste Management
      Division.  Records Center Operations Manual prepared by American
      Management Systems, Inc.  June 1989

19.    U.S. Environmental Protection Agency. Region III.  CERCLA File
      System Self-Training Course Manual prepared by Booz, Allen &
      Hamilton,  Inc. June 1989.

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20.    U.S. Environmental Protection Agency.  Office of Information
      Resources Management.  Evaluation of Regional Superfund Records
      Management Initiatives prepared by Booz, Allen & Hamilton, Inc.
      June 1989.

21.    U.S. Environmental Protection Agency.  Office of Information
      Resources Management.  Development of an Electronic Recordkeeping
      Strategy and Guidance prepared by Booz, Allen & Hamilton, Inc.  June
      1989.

22.    U.S. Environmental Protection Agency. Region V.  Design,
      Development and Implementation of a Records Management Program
      for Region V CERCLA prepared by Booz, Allen & Hamilton, Inc.  June
      1989.

23.    U.S. Environmental Protection Agency.  Office of Administration and
      Resources Management. Assessing Optical Disk Technology for Use in
      PCMD Records prepared by Booz, Allen & Hamilton, Inc. June 1989.

24.    U.S. Environmental Protection Agency, Region VII.  Waste
      Management Division. Superfund Records Center Operations Manual
      prepared by American Management Systems, Inc. September 1989

25.    U.S. Environmental Protection Agency. Contract Laboratory Program
      Purge Files - CLP Tracking System Manual - EPA Region I prepared by
      American Management Systems, Inc. 24 October 1989

26.    U.S. Environmental Protection Agency, Region I.  Analysis of EPA
      Region I TFK Building Office's Records Management Requirements  and
      Development of Improvement Options - Interview Guide and Key
      Areas  of Responsibility for EPA Region I by Division/Program/Off ice
      prepared by American Management Systems, Inc. December 1989.

27.    U.S. Environmental Protection Agency.  Superfund Document
      Management Study - Initiation Phase Report  - Preliminary Draft for
      Review and Comment prepared by Roy F. Weston, Inc. 6  December
      1989.

28.    U.S. Environmental Protection Agency.  Superfund Document
      Management Study - Initiation Phase Report  - Executive Summary -
      Preliminary Draft for Review and Comment prepared by Roy F.
      Weston, Inc.  6 December 1989.

29.    U.S. Environmental Protection Agency Office of Solid Waste and
      Emergency Response.  Concept Phase and Definition Phase for the

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      Superfund Document Management System (SDMS) prepared by
      American Management Systems, Inc. 4 January 1990

30.    U.S. Environmental Protection Agency.  Recommendations on
      Guidance for Contractors, States and Other Federal Agencies for
      Document Management - Preliminary Draft for Review and Comment
      prepared by Roy F. Weston, Inc. 9 March 1990.

31.    U.S. Environmental Protection Agency. Development for Superfund
      Indexing and Barcoding System prepared by American Management
      Systems, Inc. 12 March 1990.

32.    U.S. Environmental Protection Agency, Region IV. Inmagic Data Entry
      and Report Production Procedures for EPA Region IV Administrative
      Record Index Data Base prepared by Booz, Allen & Hamilton, Inc. 16
      March 1990.

33.    U.S. Environmental Protection Agency, Region I.  Development of
      Improved Procedures for Records Management in EPA Region I TFK
      Building Offices prepared by American Management Systems, Inc. 9
      April 1990.

34.    U.S. Environmental Protection Agency, Region I.  Region I Superfund
      Site File Document Indexing System:  System Concept prepared by
      American Management Systems, Inc. 9 July 1990.

35.    U.S. Environmental Protection Agency. Office of Information
      Resources Management. Comprehensive Analysis of Records and
      Forms Management Program in EPA Headquarters Offices: The Office
      of the Future prepared by Booz, Allen & Hamilton, Inc.  July 1990.

36.    U.S.* Environmental Protection Agency, General System and  Feasibility
      Study for Automated Support for Superfund NPL Site Records
      prepared by American Management Systems, Inc. 30 September 1990.

37.    U.S. Environmental Protection Agency. Office of Information
      Resources Management. Guidance for Developing Image Processing
      Systems in EPA prepared by Booz, Allen & Hamilton, Inc. February
      1991.

38..   U.S. Environmental Protection Agency. Superfund Indexing and
      Circulation Control System - User's Manual prepared by American
      Management Systems, Inc.

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    APPENDIX  B
"Revised Regional Information Resources
Management Model to Include Records
Management Support, " OARM/OIRM,
January 17,1989

Sample Position Description for Regional
Records Center Manager

Contractor Do' and Don'ts

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                UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                           WASHINGTON. D.C. 20460
                                                              OFFICE OF
                                                            ADMINISTRATION
                                                            iNO RESOURCES
                                                            MANAGEMENT
MEMORANDUM

SUBJECT:   Revised  Regional Information Resources Management
          Model  to Include Records Management Support
 FROM:    .  Edward  J-  Hanley,  Director
           Office  of  Information Resources Management
                                     '    }
 TO:        Assistant  Regional Administrators
           Regions II,  III,  IV,  V,  VI,  VII,  VIII and IX

           Planning and  Management Division Director,
           Region  I

           Management  Division Director,  Region X

      The  Office  of  Information Resources Management (OIRM) has
 revised the Regional  Information Resources Management (IRM)
 Model to include  records  management support.   OIRM recommends
 that the records  management  function move under the authority
 and direction of  the  Regional IRM Branch.

      The  increase in Superfund documentation has precipitated
 the development of records  management initiatives in most EPA
 Regions.   Many Regions  plan  on using the experiences learned
 from the organization and design of Superfund records management
 systems as a springboard  for region-wide records management
programs.   Currently, these  Regional initiatives are coordinated
by various groups including:   Administrative  Services Branches;
 IRM Branches; Waste Management Divisions and  Superfund Program
Units.   SOBM -of the Regions  lack dedicated records management
professionals to  direct the  design,  implementation and
maintenance of the initiatives.

      OIRM believes that  incorporating records management
support within the IRM  Branch will help ease  the problems of
the lack of consistency and  qualified personnel.   The Regional
 IRM Managers network  will provide an effective medium for
information exchange  and  technology transfer,  as well as

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assuring strong management and technical direction  for  the
records management functio_n._  Most. imporjLan-t—e4—ail,  thre—•
inclusion of records management in  the Regional IRM function
will help assure integration of records with other  information
resources and technologies.

      I have attached a revised Regional IRM Model  that
describes the records management function we believe  should be
developed in each EPA Regional Office.  We welcome  your comments
on this Model.

      If you have any questions,  please contact me  directly at
FTS 382-4465 or Steve Schilling at  FTS 382-5636.
Attachment

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                       I .  Introduction

      The EPA Regional Offices play  a  critical  role  in  the
 collection,  management and processing of EPA's information
 resources.   The EPA Regions are specifically responsible for
 reporting on the  implementation and enforcement of  most major
 Federal  environmental statutes, for documenting and reporting
 the  transactions  involved in the several billions of dollars
 provided to  State and local governments under EPA
 administered grant programs, and for measuring and  assessing
 the  environmental results of Federal and State programs to
 protect  the  environment.  The Regions are also responsible
 for  managing and  reporting on emergency and remedial response
 programs under Superfund, and for gathering and maintaining
 the  documentation required to assign responsibility for
 charges  to Superfund.

      Due to  their critical role in  the Agency's overall
 information  resources management program, the Office of
 Information  Resources Management (OIRM) assigns special
 importance to the development, support and assessment  of
 Regional information management capabilities.  Over the past
 several  years, OIRM has assigned the highest priority  to
 enhancing Regional IRM programs and capabilities,  including:

           The modernization of Regional computing  and data
           communications resources.

      •     The assessment and strengthening of Regional IRM
           organizations.

      •     The improvement of'State/EPA data management,
           including pilot State data management initiatives
           conducted by each EPA Region.

      •     The improvement of Regional records management
           systems.

      To  continue assisting and strengthening Regional  IRM
programs and capabilities, OIRM has developed and updated
this document for use in the Regional Offices which is
presented in the following pages.  This document also includes
a current listing of Regional IRM Managers, and two summary
tables on Regional IRM Organizations and Resource trends.
OIRM will be  updating this document periodically in
coordination with the Regional Offices.

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        Ill.   Regional Office IRM Organizational Model

     In both the private and public sectors, organizations
are placing increasing emphasis on managing information as an
important corporate resource.  As a result there is a
transition taking place that involves not only restructuring
the ADP organization but also implementing new management
approaches.  EPA is no exception to this growing emphasis on
information resources management (IRM).

     Increasingly much of the information used by EPA
originates within the State environmental organizations and
in the EPA Research and Development Program (ORD).   Any
effective EPA IRM program must inherently involve the States,
ideally as co-partners.  State involvement requires Regional
leadership in establishing and maintaining this EPA/State IRM
partnership.   Additionally,  EPA's ORD Laboratories collect
considerable amounts of information which requires effective
management.  Therefore, involvement of at least the major EPA
Laboratory sites at RTP, Las Vegas and Cincinnati is also
important for a successful EPA IRM program.

     OIRM promotes the continued strengthening of the
Regional Management Divisions and their RTP, Las Vegas and
Cincinnati counterparts.  OIRM recommends the following
functions for inclusion in a Regional IRM organization:

          Overall IRM  Branch and Section Management

          —     Branch  management and  secretarial support
                Support to Regional Office  IRM  Steering
                Committee
                Improvement  of  communication with IRM services
                user  community
                Development  and implementation  of
                Regional/State  IRM Plans
          -     Review  of State  grants and  programs  relative
                to IRM  support
                Oversight of all on-site  IRM contractor
                support.

     •    Central ADP  Operations and  Support

          -     Operate Computer Center
                Modernize ADP technology  in'the Regional
                Office.

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     •    Software Development and Management

          -    Provide ADP  systems management
          -    Assist EPA Headquarters in developing National
               and—Agency-wide systems .

          An additional function for the IRM Branch in this
               area could also be:

               Lab Automation.

     •    Information User Services

               Operate Information Center
               Support office automation, electronic mail and
               word processing
               Operate Library
               Support Information Security.

          Additional functions for the IRM Branch in this
               area are:

               Operate Public Information Center
               Operate Regional Map Center.

     •     Records Management Support

               Operate Records Center fsl
               Develop Records Management Life Cycle Systems .

     •     Voice, Image and Data Telecommunications

     •     Comprehensive Environmental Data Management

               Develop data integration systems
               Provide Data Base Broker Services.

A brief description of the envisioned scope of these
functions follows.

Overall IRM Branch and Section
     In addition to Branch management and secretarial
support, other functions in this category include:

     •     Support Regional Office IRM Steering Committee  —
          At the Headquarters level,  the Administrator has
          established an EPA IRM Committee.   this Committee

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is chaired by the OIRM Director.   OIRM recommends
that similar Committees be established in each
Regional Office chaired by the ARA/Management
Director with the Regional IRM Manager serving as
the Executive Secretary to the Committee.

Improve Communications with IRM services user
community   -  Good communications and public
relations between the IRM organization and the user
community it supports are essential for a
successful IRM organization.   The objective of
these regularly scheduled meetings is to keep the
users informed of both Regional and Headquarters
IRM plans as well as obtaining user input to these
plans and feedback on IRM service delivery.

Develop and implement Regional/State IRM plans  —
Each Region should continue to refine and augment
their Regional/State IRM plan.  The EPA
Administrator assigns a high priority to improving
EPA/State data management.  OIRM believes that
leadership provided by the Regional IRM
organization in drawing together Regional and State
senior program and ADP managers to improve EPA
information systems is critical to further success
in this area.

Review State grants and programs relative to IRM
support  -  The Regional Office IRM organizations
need to review EPA program grants to the States to
be sure funds that will support IRM are consistent
and compatible with Regional/State IRM plans.  In
addition to reviewing grants, the Regional IRM
manager should periodically visit the State
environmental agencies to review the delivery of
IRM services to EPA delegated environmental
programs.

Oversight of all on—site ADP Contractor Support  —
Over the years EPA has used contractors for data
handling support.  These contract resources are
funded and managed by multiple project officers.
Often the project officers are located at EPA
Headquarters and the contractor staff are located
in the Regional Office.  To maximize contractor
productivity and service, the Regional Office IRM
manager should oversee all the on-site contractor

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           data  handling  staff  in  coordination with all the
           project officers.  OIRM is not recommending that
           the Project Officers  assignments be changed but
           rather that the  Site  Manager have overall
           accountability to one EPA on-site manager, the IRM
           Manager.

Central ADP Operations and Support

           All Regional Office  IRM Branches/ADP Sections
           currently operate the central computer equipment,
           run production jobs,  provide data entry services
           and distribute computer output.  Over the next few
           years there will be  a significant modernization of
           the Regional Offices  computing resources which must
           be carefully managed  to assure a successful
           implementation and uninterrupted support to users.
           A strong Regional Office technical staff will be
           key to successful implementation fo EPA ADP
           Modernization  Plans.
Software Development and Management

     •    Provide ADP Systems Management  -  All the Regional
          Office IRM Branches/ADP Sections currently perform
          this function to some degree which includes support
          of National systems (e.g., systems used by EPA and
          the States...STORET, GICS, PCS), of Agency-wide
          systems (e.g., EPAYS,  FMS, FRDS) and development of
          local systems.  As the large National and Agency-
          wide systems are modernized, the Regional Office
          ADP staffs will play a central role in implementing
          system changes in the Regions and in the States.

          There is considerable variation as to the degree of
          centralization of this function within a Regional
          Office.  OIRM's observations are that the highly
          decentralized situation does not work well,
          primarily because the Regional Office would not
          have the "critical mass" of program systems ADP
          expertise required to not only adequately support
          the Regional Office but also to do the essential
          coordination and planning with the States.  OIRM
          recommends a more centralized approach that places
          the "critical mass" of staff with strong ADP
          experience in the IRM Branch.  This also includes
          the staff that would perform the more complex data

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retrievals that are generally beyond the
capabilities of the average end-user.

Assist Headquarters with National and Agency—wide
Systems Development  -  OIRM sees the need for the
Regional Office IRM Managers to play a more formal
and proactive role in working with Headquarters EPA
National and Agency-wide Systems Managers in
developing and enhancing these systems.
Traditionally the Regional Offices have, to varying
degrees, provided comments on the design and
participated in the testing of these EPA systems.
OIRM wants to increase the participation of these
offices in National systems development through
more formal involvement of the senior Regional
Offices' IRM professionals.  OIRM recommends a
concept where OIRM formally recognizes senior
Regional IRM professionals, based upon their
expertise, to work closely with the National and
Agency-wide Systems Managers in systems
development.  This would include coordination and
advising on the system design and implementation on
behalf of all Regional Offices plus independent
beta testing and acceptance of all system changes
in their Regional Office before Agency-wide
implementation.  OIRM will provide official
recognition of expert status to selected
individuals who have established an outstanding
"track record" at the National level in this
regard.  OIRM recommends that this expert status be
reflected in the individual's Position Description
and grade classification.

Support Laboratory Automation  —  Many of the
Regional Environmental Services Divisions use mini
and mainframe computers for laboratory data
management and other tracking systems.  This type
of ADP support is considered as part of "ADP
Systems Management" presented above.  Several of
the Regions are seriously considering the
implementation of the standard Laboratory
Instrumentation Management Systems  (LIMS) which
will ultimately enable data to be recorded,
analyzed, reported and transferred to the large
Agency data bases  (e.g., STORET) with far greater
efficiency and quality.  The implementation of LIMS
will be a key aspect of EPA laboratory automation
and modernization.  Because of the need for both

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          ADP expertise together with knowledge and
          interaction with the Agency's major program
          systems, OIRM sees advantages in assigning
          laboratory automation support to the IRM Branch.
          At the National level, OIRM is responsible for the
          acquisition of LIMS.
Information User Services
          Operate Regional Office Information Center  -  The
          purpose of the Information Center is to help end-
          users do their own computing.  The services of an
          Information Center can include consulting (e.g.,
          providing managers recommendations on office
          automation),  training (e.g.,  Electronic Mail,
          Lexitron,  PCs, PRIME, ADABAS/NATURAL) ,  providing
          technical assistance  (e.g.,  helping an  end-user
          develop a LOTUS 1-2-3 spreadsheet application),
          performing the file server role (e.g.,  finding the
          automated data and transferring it into a suitable
          format for the end-user),  and troubleshooting
          problems that end-users are unable to resolve
          themselves.

          The Information Center will provide the primary
          support for implementing and maintaining personal
          computers (PCs) and providing IRM training in the
          Regional Office.   Encouraging end-user  computing is
          important because it can improve personal
          productivity and decision-making and also conserve
          the ADP professional staff for more technical and
          complex projects.

          Support Office Automation.  Electronic Mail and Word
          Processing  -  OIRM views  this support  as part of
          the Information Center functions described above.
          Some Regional Offices currently have this support
          split between the ADP and  Administrative'Services
          function.   As the office automation,  the
          telecommunications and the traditional  ADP
          computing environments become more and  more
          integrated,  OIRM believes  that it is critical that
          this support  be provided by the IRM organization.

          Operate Regional  Office Library  -  The Regional
          Offices have  traditionally operated libraries and
          generally,  the library was separate from the ADP

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          organization.  Changing technology is resulting in
          increased use of automated data bases by libraries.
          The EPA Libraries are retrieving data from non-EPA
          systems just like the ADP organizations are
          retrieving data from EPA systems.

          Support Information Security  —  Technological
          advances are having a significant impact on
          information security and records management.  An
          ever increasing amount of information is being
          stored in electronic form (e.g., Lexitron and PC
          diskettes, PC and PRIME hard disks)  which is
          prompting many managers to rethink procedures and
          controls for storing information.

          Operate Regional Public Information Center  -  At
          Headquarters and in Regions VI and IX this function
          is part of the IRM organization.  At these
          locations,  the function is closely associated with
          the library which also provides information to the
          public.

          Operate Regional Map Center  —  In Region II this
          function is managed by the IRM organization.  The
          centralized map room is located adjacent to the
          Regional Computer center which produces map
          overlays showing pollution sources and other
          relevant data in EPA and State systems.  OIRM
          recommends that, where practical, the Map Center be
          an extension of the Library.
Records Management Support
     OIRM recommends that the records management function be
centralized and coordinated by the Regional IRM Branch.  All
Regions have initiated or implemented a Superfund Regional
records management program and foresee expanding the use of
records management techniques into other programs.
Coordination of the records management function by.the
Regional IRM Branch will help reduce duplication of efforts
by programs by providing the structure for communication of
previous efforts and new technologies. Regions are currently
addressing records management in a variety of ways:
                            8

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 Operate  Records  Center(s)   -   Region  IVs
 initiative  to  create  a  centralized  records center
 and  Region  VI's  implementation of a centralized
 program  records  center,  are managed by the IRM
 Branches.    Region  II has  a similar Records Center
 managed  by  the Permits  Administration Branch which
 is part  of  the Management  Division.  Regions I and
 III  have established  centralized records systems
 managed  by  the Superfund program.   Region X is
 planning a  records  management  system coordinated by
 the  Superfund  program.   Regions V and IX are
 organizing  documents  under the direction of the
 Waste Management  Division.  Region  VIII is
 implementing a Superfund records management system
 led  by a Special  Superfund Coordinator in the
 Assistant Regional  Administrator's  office.  The
 Program  Integration Branch, under the direction of
 the  ARA, in  Region  VII  is  planning  a records
 management  system.  Many of the initial efforts to
 design and  implement  a  records management system
 were driven  by the  immediate needs  of the Superfund
 program  which  has rapidly  increasing volumes of
 documentation  and legislated demands such as the
 Administrative Record and  cost recovery.

 Records  management  is the  foundation for numerous
 other information systems  and  requires dedicated
 personnel (FTEs)  to effectively carry out tasks
 associated with creation,  classification,
 maintenance  and disposition of records.  As a base
 each Region  should  have  at least one FTE dedicated
 to records management.   Additional  FTEs or
 fractions should be added  based on:  the size of
 the Region,   number  of NPL  sites, the current state
 of records management,  the future records
 management plans  (advanced technologies') and
 anticipated  office  moves.

 Records  Management  Life  Cycle  -  The life cycle
approach to  records management, which focuses on
the management of records  from their creation
through  their  maintenance, use and  disposition, has
been a primary operating procedure  for several
years.  There  has been a new emphasis on the
 records management  life  cycle  because of the high
growth rate  in records volume  and the permanent
nature of Superfund records.   Several different
approaches to  the records management problem have

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           been tried in the Regions with great success .
           These initiatives focused on records capture,
           classification and records control.  Records
           capture entails the steps to ensure that all
           appropriate and relevant documentation is included
           in the records management system.  Records
           classification involves methods for categorizing or
           classifying documentation.  Records control
           involves the steps taken to ensure that integrity
           of files is maintained and that they are disposed
           of as necessary.   Together, these processes help to
           effectively manage records.  Detailed information
           on the status of records management programs within
           the Regions can be obtained from QIRM.
Voice. Irr.agg and Data Telecommunication and Networking

      Telecommunications  is  extremely important to the
operations of EPA.  The  Regional Office IRM organizations are
playing a critical  role  in  the modernization of the EPA data
telecommunication network.  This is  particularly true as the
network is extended out  to  the States.

      Currently, most  IRM Branches/ADP Sections are
responsible for data communications  but not for voice and
image  (e.g., facsimile)  communication.   As  communications
technology continues to  quickly evolve,  common technical
solutions are now being  employed to  support data,  voice and
image communication.  For example, the  same wires and multi-
wire  cables used to connect the telephones  can be used
concurrently for connecting PCs to local computers.  This
becomes more significant as the Agency  moves toward computer
workstations on every desk.  Also, this type of technical
expertise is in short supply and the resources available in a
Region to perform this function are  small.   Therefore,
consolidating the responsibilities for  data,  voice and image
communications can  be advantageous from both a technical and
resource standpoint.  At the National level these functions
are now consolidated in  the National Data Processing Division
(NDPD).

("!omnrf>hgngiv£ Environmental Data Management
^™^™™——^™^"'^™—™^—^^^^B^^*^"^™l^^^™™™'^"^™^~^™™^^"™^"—™^*^~^^"—^~"^™^^^^™™•^•^^™"—^™^^^™^^"^^^™^^

      Region IV recently  implemented  an Office of Integrated
Environmental Analysis  (OIEA) to develop data integration
techniques to support both  Regional  and State program
offices.  OIEA works closely with  its sister organization,
                           10

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the Information Management Branch to perform the functions
described below.  Overall coordination for these functions is
provided by the ARA for Policy and Management.

     •    Develop Data Integration Systems  -   The Regional
          Offices have a history of investing resources in
          innovative approaches to integrating,  analyzing and
          displaying information in National systems.  Some
          examples are Region VIII's Environmental Index
          Project, Region II's Facilities Index and
          Environmental Mapping Systems and Region IV s
          recent geographic information systems efforts.
          These projects usually cut across EPA and State
          organizational lines, are multidisciplinary in
          nature and receive varying degrees of support from
          Headquarters offices.  OIRM recommends that the
          Management Division, due to its involvement with
          all programs, be the focal point for at least the
          management of the IRM aspects of these projects.
          This is consistent with OIRM's responsibilities at
          the National level where the environmental systems
          integration responsibilities are assigned to OIRM's
          Program Systems Division.   OIRM seeks a very close
          and productive working relationship between the
          Program Systems Division and those Regional Offices
          which implement data integration systems that have
          potential National application.

     •     Provide Data Base -Broker Services  —  The future
          successful and widespread use of environmental data
          integration systems  will depend greatly on the data
          base quality and accessibility.  This is a complex
          area because there is a considerable amount of
          useful,  automated environmental data but generally
          it is very decentralized.   Within EPA, much of
          these data are available on either the NCC-IBM or
          Sperry Computers but the data bases are managed by
          many different people and organizations.  Also the
          EPA data represents  only a portion of what is
          available.   Other potential data sources are USGS,
          SCS,  NOAA,  Census Bureau,  State and local
          governments,  interstate agencies and commercial
        .  sources  (e.g.,  Dun & Bradstreet) .   Advising
          Regional and State staffs  on what automated data is
          available,  who to talk to  about data quality and
          how to obtain access to the data are functions that
          need to  be performed by a  Data Base Broker.  For
          those non-EPA centralized  data bases that are
                          1 1

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needed by Regional and State staffs on a regular
basis, the Data Broker would also develop
arrangements for these data bases to be more
readily available (e.g., updated copies made
available on the EPA central or Regional
computers).   OIRM recommends this function be
assigned to the Regional IRM .organization and,
further, that it be closely allied with the Library
and Information Center functions.  In addition to
brokering access to automated data bases outside of
EPA, OIRM recommends that the Data Broker
facilitate the resolution of cross-system data
quality issues within the Region.  For example,
establishing uniform facility naming conventions or
negotiating commitments from individual system
managers for completion of latitude-longitude data.
                 12

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               INFORMATION  MANAGEMENT SPECIALIST
                           GM-301-14

I. INTRODUCTION

     This position is located  in  the Office  of  Administration
and Resources Management, Office  of  Information Resources
Management, Information Management and Services Division,
Information Access Branch.

     The Information Management and  Services Division  (IMSD)
is responsible for formulating and implementing the Agency's
Information Resources Management  program to  manage and  •
enhance the collection,  reporting, storage,  manipulation,
analysis, and use of records generated by EPA.  The mission
of the Information Access Branch  (IAB) is to disseminate and
provide access-to environmental information.  IAB is
responsible for leadership and service in providing
environmental information to EPA  staff, managing access to
EPA records and providing public  access to EPA  information
sources.  Efforts are directed at improving  the availability,
accessibility, timeliness, and usefulness of information.
IAB responsibilities include assessment of Agency need and
public demand for information, and definition,  creation,
implementation and maintenance of effective  programs for
providing information, including  coordination of libraries,
public information contacts, dockets  and records centers in
Headquarters, Regions and laboratories.

     The primary purpose of this  position is to provide
policy development expertise and  senior analytic support to
the Branch Chief in assessing and defining the needs of
Agency managers for records management, and  developing and
implementing effective programs for  meeting  those needs. A
major function of this position is to serve  as  the primary
liaison with the Office of Emergency  and Remedial Response
(OERR)  to provide consultation, technical advice and
implementation support for managemento fo OERR  records in
Headquarters and Regional offices.

II.   MAJOR DUTIES

     The incumbent has primary responsibilities for
developing and implementing a strategy for revitalizing
records management functions.consistent with Office of
Management and Budget Circulars A-130' on establishment of
Federal Information Resources Management (IRM) Programs.  The
incumbent establishes Agencywide  policies,  procedures,  and
guidance in several specialized areas of information
management,  including archival management,  vital records
management,  document creation and maintenance, training, and
other advanced office management  information  and
documentation systems.  The incumbent is responsible for

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planning, organizing, and directing studies,  surveys,  and
special projects in these areas,  and for developing and
coordinating Agencywide program audits and evaluations.
These studies and program evaluations include analysis of
information needs to design new or modified documentation
systems, and assessment of the_-eJ: f icieney -of enisling "systems'
in accomplishing management objectives.

     Negotiates with officials at the various organizational
levels involved during the conduct of studies, and seeks
their approval or comment on the preliminary and final study
conclusions and recommendations.   Many of the operating
procedures and systems under study are interrelated with
those or other organizations or systems.  These must be
coordinated or adjusted with the organizations or systems
managers involved.  The incumbent is required to present oral
and written study findings and recommendations to a broad
range of Agency officials.  Provides technical assistance and
training- to program officials during the implementation of
the recommendations.

SPECIFIC RESPONSIBILITIES OF THE 'INCUMBENT ARE AS FOLLOWS:

1.  Program Planning.  Keeps abreast of legislation and
regulations administered by and imposed upon the EPA and
studies their effect to determine the objectives and
obligations of the Agency.  In relation to the Agency
requirements, conceives and determines the nature and
dimensions of the management functions necessary to keep pace
with new developments and changes in Agency programs,
functions and organizational structures.  Establishes
objectives to be attained in information management program
areas.  Plans the conduct of surveys to respond to requests
assistance.  Initiates periodic evaluation surveys in the
various Agency organizations.  Formulates and recommends
policies that will achieve these objectives, maintaining
liaison with line managers^ on matters of mutual interest
concerning requirements. ^Assumes responsibility for
integrating records management into a complete and
comprehensive program, and for developing immediate and long-
range plans this area.
2.  Program Implementation and Administration. -Provides the
records management staff with policy guidance and the
framework for the further detailed development,
implementation, and operation of the various aspects of
program area.  Reviews implementation plans developed by
staff members ensuring completeness of coverage, determining
emphasis needed on specific areas, and otherwise ensuring
that these plans are realistic and appropriate in relation to
Agency needs and objectives and the capabilities of the staff
to provide assistance.  Maintains liaison with other

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 Government agencies to exchange  information  and  ideas  with
 view to keeping abreast of the state  of  the  art  and
 installing modern practices and  innovations.

 3.   Program Appraisal. \ Establishes and  directs  and system
 for the evaluation of records management practices  to
 determine the overall effectiveness of the program  throughout
 the EPA."^1 Analyzes survey findings, reports,  and other
 documents concerning effectiveness of program;  identifies
 strengths and deficiencies in the various areas,  and
 recommends appropriate improvements.
 4.   Program Services.   Provides  direction  to  Records
 Management  Staff engaged in  day-to-day  services.   This
 includes  records retirement  and  retrieval,  review  of  file
 equipment requests,  procedural guidance to secretaries  and
 file clerks,  and interpretation  of  records procedures.   Keeps
 in  touch  with status and progress of  work  and adjusts
 priorities  when  necessary, maintaining  balance between
 Headquarters  service and Agencywide management.
 5.   Information  Resources  Management   Plans,  develops  and
 coordinates  a  certification  program which delegates  records
 management  functions  to EPA  program and  regional  offices  and
 establishes  a  records management  program integrated  with
 EPA's  IRM program and policies.   Designs and  conducts  a
 program for  certifying records management officers as  a basis
 for  delegation.   Training  may be  provided by  the  incumbent,
 other  Agency personnel or  contractor/consultants. ^Develops
 tools  promoting  the effective coordination of decentralized
-records management activities, e.g.,  automation of the
 retention and  disposition  schedules processes, tp ensure  the
 accessibility  and security of EPA information^ iProvides
 advice and technical  assistance to records management
 officers on  IRM  policy and the interpretation of  all related
 Federal laws,  regulations  and guidelines.  Serves as the
 project manager  on studies to resolve IRM~^issues  in  records
 management and advises senior Agency  managers and the  IRM
 Steering Committee on all  matters related to  records
 management.
 6.   Vital  Records:   Develops,  coordinates, and  conducts
 Agencywide comprehensive  studies  of  vital  records  management
 programs which  provide  for  the  immediate and  sustained
 operations of EPA in the  event  of a  national  emergency or
 national disaster.   Maintains  liaison with program officials
 to  determine their emergency information and  documentation
 requirements and  provides technical  assistance  concerning the
 preservation of this information  at  a protected site.
 Develops EPA issuance providing procedures and  instructions

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designating these vital information resources and specifying
the optimum media for storage at the site.

7, 'Creation and Maintenance, of Records  Develops and promote
an Agencywide program for the creation and maintenance of the
Agency's records.  Establishes control and provides guidance
to program officials to insure that important policies and
decisions of the Agency are adequately recorded,  routine
operational documentation is kept to a minimum,  and the
accumulation of unnecessary documents in prevented.

     Provides guidance to program officials to insure there
are effective management controls over the maintenance and
use of information.  Specifically,  studies analyzes,  and
provides recommendations concerning the selection of the most
efficient and cost-effective storage and retrieval equipment
for all types of information documentation systems, including
information systems.  All systems are evaluated to determine
if the reference and retrieval requirements justify automated
or semiautomated storage equipment.
SUPERVISORY CONTROLS

     Receives general direction from the Chief, Information
Access Branch,  in the form of broad guidelines, policy, and
program objectives,  and completion time constraints of the
project assignment.   Work is reviewed to determine
accomplishments as reflected in reports, management
assistance, advice,  and counsel provided to Agency managers
and conformance with the Federal Records Act of 1980, as
amended,  and Executive Order 11921, as implemented by 41 Code
of Federal Regulations 101.

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             CONTRACTOR DO'S AND DON'TS

-Developing the Work Assignment

 DO:       Clearly define the type of work to be done and any
           specifications or standards to be adhered to

 DO:       Include the following information in the work
           assignment:

                A work assignment number
                A title
                A brief description of the work to be performed
                An estimate of the period of performance
                A statement of work.

 Preparing the Statement of Work

 DO:       Clearly define the scope of the work involved and
           specific products the contractor is expected to provide.

 DO NOT:  Assume that the contractor will do the expected work;
           the work must be clearly defined and described.

 Reviewing the Contractor Work Plan

 DO:     Review the work plan to ensure that it contains:

           •    An overall plan  to accomplish the assignment
           •    A timetable for completing the assignment
           •    Anticipated  problems within  the assignment
           •    A detailed listing of contractor personnel
                devoted to the assignment
           •    The hours expended by each member of the
                contractor team
           •    A listing of all other direct costs and the total
                cost of the assignment
           •    Detailed resumes of the contractor personnel
                on the assignment.

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        CONTRACTOR DO'S AND DONTS continued

Providing Technical Direction

DO:       Provide the contractor with any additional, requested
           technical guidance.

DO NOT:  Modify the scope of the work plan.  Only the
           Contracting Officer has the authority to alter the
           scope of a work plan.

DO:       Contact the Contracting Officer if you have any
           questions regarding your interpretation of the
           work assignment.

Tracking Contractor Progress

DO:       Monitor the  contractor's performance on a
           regular basis.

DO:       Maintain regular communication with the
           contractor.

DO NOT:  Rely solely on written monthly reports for
           progress information.

DO:       Monitor the  contractor's work.

DO NOT:  Manage the  contractor's work.

Reviewing Monthly Progress Reports

DO:       Ensure that  the contractor provides comprehensive
           monthly reports including a technical progress report
           and a financial progress report.

Quarterly Reviews

DO:       Cover all issues relating to the progress of the
           work assignment, especially any problems that
           may have arisen during the review period.

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        CONTRACTOR DO'S AND DONTS continued

Reviewing Invoices

DO:       Review all invoices carefully and verify that all
           charges are acceptable and relate directly to the
           work performed during the billing period.

DO:       Review all invoices in a timely  manner.

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   APPENDIX C
Applicable Guidance Report

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                   U.S. ENVIRONMENTAL PROTECTION AGENCY
               OFFICE OF INFORMATION RESOURCES MANAGEMENT
        '-r                        401 M STREET S.W.
        z                    WASHINGTON, DC 20460
O V XTV / O

\.
                MODEL REGIONAL RECORDS
                 MANAGEMENT OPERATING
                     PROCEDURES MANUAL

   APPLICABLE GUIDANCE REPORT
                                November 1991
              f ffff ffr fjyyf/ftt f

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                  TABLE OF CONTENTS
I.    Executive  Summary   	1
II.   Approach
III.   Summary of Documents  	5
IV.   Appendix	•	13
                                       Applicable Guidance Report

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                          I.   EXECUTIVE  SUMMARY
       In order to develop an understanding of the factors affecting the Regional implementation
of records management procedures, Booz» Allen & Hamilton Inc. conducted a review of current
EPA policy and guidance documents, as well as relevant records management studies, Federal
statutes, and National Archives and Records Adminisffatkm (NARAXana ueneral Services
Administration (GSA) instructional materials.  These documents were reviewed to determine their
relevance to 13 specific records management issues, such as budget constraints, security, public
access, the records life cycle, and technology options. The results of this review provided the
groundwork for determining the relationships between existing Regional records management
practices, mandated requirements, and a model Regional records program (which will be
developed and described in forthcoming deliverables).

       This initial document review revealed that for many areas of records management,
requirements, and in some instances procedures, are clearly defined.  Examples of these areas
include procedures for records disposition, equipment acquisition, and Freedom of Information
Act (FOIA) requests. NARA and GSA guidance also provides extensive information on creation,
maintenance, and use of electronic records. However, most of these documents rely on the
assumption that a comprehensive records management infrastructure already exists, and that the
reader has a basic knowledge of records management principles . In many of EPA's Regional
offices this is not the case. Several of the Regional offices are in the beginning phases of their
records management programs and require additional "hands-on" information to support the
creation and maintenance of a program.

      Additionally, several of the EPA-specific documents, particularly the Records Management
Manual, contain dated information which no longer reflects requirements mandated by NARA,
GSA, and a changing records management environment and information that does not depict
current Regional records management practices and needs. Furthermore, the existing records
management guidance is incomplete in that it does not provide adequate detail on certain records
management issues.

      Specifically, the following areas were either not addressed or were not adequately covered
in existing records management guidance:

      •      Practical steps for initiating a Regional records management program

      •      Detailed records center structure and operations procedures

      •      Management support for the vital records and security programs

      •      Budgeting and planning information and support across programs

      •      Specific guidance for training in records management principles and technological
             applications

      •      Requirements and procedures for handling cross-program issues

      •      Guidelines for dealing with increasing public access requirements

      •      Guidance for selection and use of technological applications

      •      Disposition schedules that reflect actual file structures.
                                                       Applicable Guidance Report

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                                                               Executive Summary
       For a model Regional records management program to be successfully designed and
implemented, these areas must be further defined. Additional information gathered with regard to
specific Regional needs in these areas will allow incorporation of these elements into the
development of a model Regional records management program and its Records Center operating
procedures.
                                                        Applicable Guidance Report

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                                 II.  APPROACH
Background
             i

       During the last two years, EPA's Office of Information Resources Management (OIRM)
has been examining the organization and functions of both Headquarters and Regional records
management programs.  As a result of this examination, OIRM has determined that Regions would
benefit from additional guidance to assist the program offices in implementing records management
activities.  Booz» Allen & Hamilton Inc. is helping OIRM in this effort to provide Regions with
records management assistance through developing a model for a Regional records management
program, including a Records Center and then, subsequently, a Model Regional Records
Management Operating Procedure Guidance Document. This Document is intended to enable
managers to develop a coordinated and consistent, region-wide approach to records management
and to develop Regional Records Centers.

Purpose of  Report

       This document, the Applicable Guidance Report, is the first step in the completion of the
Operating  Procedures Guidance Document. This purpose of this report is twofold. First, the
report provides an initial understanding of many of the functional issues which impact the Regional
implementation of records management procedures. This understanding was obtained through a
review of current EPA and other Federal government policy, guidance documents, and records
management studies and is conveyed in the  report on a document-by-document basis. Secondly,
this report evaluates this body of documents and identifies functional areas for which the present
policy and guidance available to the Regions could be improved.  This identification provides focus
for remaining tasks through highlighting primary areas of concern which need to be reviewed in
depth for inclusion in the Operating Procedures Guidance Document.

Approach  to Report

       The approach to completing this report involved three phases. The first phase centered
around the review of the previously mentioned EPA and other Federal government documents.
The documents that were reviewed in this section are listed in the Appendix.  These documents
were reviewed to determine the information  they provided on relevant records management issues.
These records management issues were identified, as a result of discussions with OIRM, to be the
following:

       •      Budget Formulation/Constraints -- the financial resources necessary  and/or
             available for implementation  of the records management program

       •      File Inventory/Structure -- the organization of the records or files in terms of the
             regulatory or program requirements

       •      Security -- the safeguarding  of the Agency's information resources

       •      Vital Records — the protection of those records critical to the continuation of the
             Agency's essential services in an emergency

       •      Public Access - ensuring that records storage procedures are consistent with the
             requirements of the Freedom of Information Act (FOLA) and other regulatory
             requirements for public access to certain documents
                                                      Applicable Guidance Report

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                                                                        Approach
       •      Staffing — personnel resources needed to support the records management program
             and the definition of the necessary skills and functions that are incorporated into the
             staffing plan

       •      Space, Equipment, and Materials -- capital resources necessary, including the GSA
             space requirements, OARM guidelines regarding the purchase of storage equipment
             and records handling materials, and other considerations in determining the mix of
             space and equipment needed

       •      Records Center Structure and Functions — the design and primary responsibilities
             of the file room or "records center" as defined by Agency program needs or
             regulatory requirements

       •      Life Cycle Functions ~ the requirements of the records management program as
             they apply to the stages of the record's existence, from creation, through use of the
             record and ultimately, record disposition/archival

       •      Organizational Options --  the options for integrating the program needs with the
             Agency's operating structure, including the responsibilities and involvement of
             upper-management staff

       •      Technology Options -- the options for applying technologies to accomplish
             recordkeeping functions and the appropriate mix of technologies, as well as
             guidelines for the creation of innovative technology applications to meet special
             program needs

       »      Cross-Program Information Integration -- the interaction of Agency program data
             and the subsequent impact of such on the structure and functions of the records
             management program

             Training - the background skills development and ongoing  instruction necessary to
             instill the appropriate mix of skills for the records management program staff.

The document reviews are presented in the Appendix of this report. Each review covers one
document and is structured in two main sections: Document Overview and Applicability to
Regional Records  Management. The Document Overview section conveys  general information
about the contents of the document and the audience for the information.  The Applicability section
is divided into the  previously mentioned records management categories and describes the type of
information found in the document for all relevant categories.

       After the review of the individual documents was completed, the  second phase of this
report began.  This phase involved examining the collection of documents as a whole to specify
strengths and  areas for improvement as they related to the records management issues. This
examination included identification of issues which were not covered sufficiently by the existing
guidance and  areas for which the existing information was satisfactory. This phase also drew
upon the  information provided in the records management studies. These studies offered the
perspective of several regions with regard to their records management experiences and needs.

       In the final phase of this report, the information obtained in the first two phases was used
to target the records management issues about which additional information needs to be gathered in
subsequent components of the study.  Gathering this information will allow these issues to be
factored into the development of the Model Regional Records Management Operating Procedures
Guidance Document.


                                        4               Applicable Guidance Report

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                      III.   SUMMARY OF  DOCUMENTS
        In reviewing the resource documents selected for this project, attention was focused on
the basic administrative and legal requirements provided for in the guidance, directives, and policy
developed by NARA, GSA and EPA; these requirements were considered in context with the topic
areas introduced in the Approach section of this report. These topic areas include identified
Regional records management program requirements and the procedures that support a Regional
Records Center.

        While the majority of the documents reviewed for this project, under the heading
"Directives/Guidance," contain legal and administrative requirements for conducting records
management, various studies and other resource materials, which provided information on the
practical application of these requirements, were also reviewed and appear  under the heading
"Studies/Other Resources." These documents either apply subjective analysis to existing
programs, or provide element(s) of the framework necessary to manage EPA's records.

        The following sections include a general evaluation of the applicability of guidelines on
which to base the development of a model Regional records management program.   Exhibit-1 is a
graphic representation of the topic areas covered by each document.


                               Directives/Guidance

Budget  Formulation/Constraints

       No significant information on this topic area was included in the documents reviewed.

File Inventory/Structure

        A NARA guide published in 1988 contains questions designed to  help records
management personnel develop and maintain an effective filing system that promotes prompt
retrieval of records. Another questionnaire is designed to help save costly storage space by
identifying non-record material. Public access regulations found in the FOIA manual and
Superfund Administrative Record guidelines mandate the existence of an inventory of existing
records series.

Vital  Records

        The EPA Records Management Manual and  the Revised IRM Model define vital records
and the purpose of the vital records  program and delineates the responsibilities of key personnel.
Various NARA publications define  a process for identifying vital records, and provide guidance on
methods of vital records maintenance.

Security

        The Information Security Manual implements the Agency's security policy, addressing
availability, integrity and confidentiality, specifically outlining minimum security controls for
computer installations. NARA rules and GSA guidelines on electronic records management outline
requirements for electronic records security, including restricted access, backup and  recovery
mechanisms. An OMB Bulletin provides guidance for the development of security plans for
computer systems, including training and technology approaches.
                                                       Applicable Guidance Report

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                                       EXHIBIT - 1
                       DOCUMENT REVIEW SUMMARY
    CATEGORY
            DOCUMENT
            TITLE
II
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oo O

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    e
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                                 0 =
Agency Records Management Evaluation
Electronic Records Management Final Rule
Electronic Recordkeeping
EPA Information Security Manual
Establishing and Managing a Records
Management Program
Evaluating a Vital Records Program
Evaluating Fries Maintenance and Records
Disposition Programs
Executive Order 12656 - Assignment of
Emergency Preparedness Responsibilities
Federal Archives and Records Centers
Forms Management
Freedom of Information Act Manual
Information Resources Management Policy
Manual
 Information Resources Management
 Strategic Plan
                                                          Applicable Guidance Report

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                                          EXHIBIT -  1
                         DOCUMENT REVIEW SUMMARY
    CATEGORY
             DOCUMENT
             TITLE
Budget Formula
Constraints
nventory
Recor
Access
Publ
Space. Equip
Materials

Records Cente
and Functions
cle Fu
ife
$
I
o
X
Cross-Prog
Integration
a»
•f
'5
 Instructional Guide Series: Managing
 Audiovisual Records
Instructional Guide Series: Managing
Cartographic and Architectural Records
 Instructional Guide Series: Managing
 Electronic Records
 Interim Guidance on Administrative Records
   Selection of CERCLA Response Actions
Micrographics 36 CFR Part 1230
Records Management Handbook:
Disposition of Federal Records
Records Management in the EPA: An
Overview for Regional Managers
Records Management Program Field
Evaluation. Environmental Protection Agency
Region 4	
Records Management Regulations:
Final Rules
Revised Information Resources
Management Model
Study to Evaluate Regional Superfund
Records Management Initiatives
Superfund Document Management
Study - Initiation Phase Report
Svstem Life Cycle Guidance - 9028
vnai Records During an Emergency 36 CFR
Part 1236
                                                            Applicable Guidance Report

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                                                           Summary of Documents
Public  Access

        FOIA regulations document the policies that must be followed in determining what
information may be released, what procedures must be followed to track and file the request, and
what fees may be assessed. Guidance document^ on Electronic Recordkeeping address the
regulation3~|oveming proper controls over classified or proprietary information stored
electronically.

        Public access rules particularly influence the requirement for Regions to have a structured
organization of all program files to enable access to requestor-specified records.

Staffing

        GSA provides guidelines on establishing a management program for electronic records,
including general responsibilities for both managers and staff; minimal guidance is available on
electronic records responsibilities of EPA staff members. The EPA OIRM records management
manual describes general responsibilities of staff members in many areas.

        The GSA forms management handbook outlines particular skills required by forms
management staff, and provides criteria for determining the size of staff needed to support a
program.

Space,  Equipment  and  Materials

        Various guidance documents outline general procedures for the acquisition of filing
equipment and supplies; the majority of the guidance materials simply suggest factors that should
be considered prior to purchasing new equipment, provide  guidelines for determiningjequirements
for electronic equipment and supplies, as well as establishing minimum environmental standards
for maintaining microform and other equipment.

Records  Center Structure and  Functions

        No information on this category was included in the guidance documents reviewed.

Life Cycle  Functions

        Numerous guidance documents give some degree of attention to providing objectives and
suggesting general responsibilities for the basic records management  life cycle functions.

        Requirements for the creation and use of data files in electronic  format are found in
NARA and GSA guidance. Numerous documents, including NARA rules, outline requirements
for creation, use, indexing and retrieval, retention and destruction of electronic records.

        Extensive documentation exists on the disposition requirements for all Federal
government records, including cartographic, microform, audio-visual, and electronic data.
                                                       Applicable Guidance Report

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                                                          Summary of Documents
Organizational  Options

        Various documents addressing security and vital records propose management and
organizational structures to oversee these functions.  Similarly, discussions in several electronic
recordkeeping documents provide guidance on establishing a management structure, detailing its
place in the organizational hierarchy.  The Records Management Manual suggests responsibilities
for various offices throughout EPA.

Technology  Options

        A GSA document on electronic recordkeeping discusses advantages and disadvantages of
data base management systems and full text retrieval systems as options for indexing and retrieval
functions.  The OIRM Records Management Manual provides information on justifying the need
for a micrographic system; it also includes articles on optical disk, computer-assisted retrieval
systems, and image management systems. OIRM has granted approval for the Superfund
Administrative Record file to be maintained on microform.

        Automation devices currently available for forms design, composition, and typesetting are
discussed in the GSA forms management handbook. The NARA rule on electronic records
management states that Federal agencies should define their requirements for selecting appropriate
maintenance and storage technologies.

Cross-program  Information  Integration

        A recent NARA rule on electronic records management suggests that standard interchange
formats between various agency  systems should be developed. OIRM policy states that data
standards should be set to provide consistent definition  of data and facilitate cross-media use of
data.

Training

        Executive Order 12656  Assignment of Emergency Preparedness Responsibilities
discusses the need for training  and education programs  that incorporate emergency preparedness
(security/vital records).  Published Rules on electronic records management call for training
appropriate agency personnel to safeguard sensitive or classified records, as well as training in the
operation of media used in a system. The EPA Information Security Manual states that OARM is
coordination the development of information security training programs for the Agency.


          Records Management  Studies/Other  Resource  Materials


Budget  Formulation/Constraints

        The IRM Strategic Plan provides priorities and goals within the IRM arena and identifies
some funds (e.g., grant funds) that are available to support attainment of the long-range IRM
goals.

        In a study done to evaluate Regional Superfund records  management initiatives
discussions of budget formulation for the planning stages are summarized and funding sources and
options used by the Regions are presented. Resource constraints experienced by the Regions are
                                                      Applicable Guidance Report

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                                                           Summary of Documents
addressed, as are budget constraints affecting the outlook for the program as OIRM plans for
anticipated needs.

File  Inventory/Structure

        Regional studies characterize the features of the Superfund program and other program
files and observe that there is little or no standardization of filing systems.  In addition, according
to these studies, some of the Regions have not conducted an inventory of their .records.

Vital Records

        A vital records/disaster recovery plan checklist is included in the handbook "Establishing
and Managing a Records Management Program" published by OSWER IMS, and the revised IRM
model discusses the life cycle approach to vital records by identifying specific functions to be
employed by the records center. The Superfund Doeument Management (SDM) Study asserts that
there is not a viable security program established for the Superfund records, and recommendations
are made for establishing a practical process to  identify and handle essential" documents.

Public  Access

        One study discussed Regional limitations to responding to FOIA requests in terms of
staffing constraints.  The study also noted the amount of time spent by staff responding to
requests. The Strategic Plan states that the need for sharing information with the public requires
re-examining some of the information services (e.g., records centers, dockets, etc.) that were
initially developed, managed, and funded primarily to serve internal needs; the Plan also suggests
that public access should be considered in the development of any new systems.

Staffing

        Records management roles and responsibilities for various levels of Regional
management are outlined in the OSWER IMS handbook. The Revised IRM Model presents
records management staff functions in terms of the primary functions of the records management
program and associated personnel needs for the Regional program, noting primary variables to be
considered in the allocation of personnel. The SDM Study assembled data on the staffing costs
associated with existing filing,  retrieval, copying, and distribution activities in the Regions.  In the
field evaluation  study of Region IV, the Region's practice of rotating a records center officer
through the program offices is  supported. Regional records management staff and functions are
described and perceptions regarding available staffing resources are discussed in OIRM's
evaluation of Regional Superfund records management initiatives. Finally, the Strategic Plan
expresses a need and a commitment to attracting and retaining highly skilled IRM experts to
manage the Agency's increasing investments in advanced technology.

Space, Equipment and Materials

        The OIRM evaluation of Regional Superfund records management initiatives provides
equipment descriptions and innovative methods for obtaining space in the program planning
stages. The SDM Study documents existing costs associated with floor space and off-site storage
in the Regions; a space planning checklist is offered in the OSWER IMS handbook. Equipment
needs and options for the system are presented  in light of the support to be provided by'OIRM
under the new model.  Information user services are outlined, such as the Regional Office
                                       10               Applicable Guidance Report

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                                                           Summary of Documents
Information Center, and the Regional.Office Library. The Strategic Plan provides insight on the
review and scrutiny received from OMB during large and small procurements. The Plan also
discusses the development by OIRM of Agency-wide information architectures for program,
administrative, and scientific systems and hardware telecommunications'.

Records Center Structure  and  Functions

        The SDM Study describes the problems inherent in most existing Regional central
facilities, including lack of file security and integrity, duplicating efforts, and dealing with diverse
file structures across program records series. The revised IRM model cites advancements of
certain Regions as examples of the implementation of centralized records centers.

Life Cycle Functions

        The SDM Study briefly summarizes the current procedures in place both at Headquarters
and in the Regions for the creation, distribution, storage, and retrieval of Superfund records. A
field evaluation of Region IV  suggests that the Region give careful consideration to its present
practice of utilizing contractors for all of its records management program needs; knowledge and
expertise of records management is not being developed among EPA managers.  A similar study in
Region X reports various criticisms, including records schedules that are out of date, with
provisions of the EPA records schedule not being applied; duplication of information; and lack of
identification of essential records, or provision for their archiving. The Strategic Plan states an
objective of providing appropriate technical assistance and client support to facilitate efficient use of
resources to ensure effective and appropriate handling of Agency records,

Organizational Options

        In the evaluation of Regional Superfund records management initiatives, options for
implementing the program are provided from several Regional records management perspectives.
Modifications to the initial structure are also provided to assist in anticipating issues related to
program organization and anticipated growth. The SDM Study proposes a preliminary project plan
with a high-level concept for the development of a Superfund Document Management System that
would drive the handling of all Superfund documents.

Technology Options

        Several components  of the IRM program's mission statement revolve around technology,
especially the need for EPA employees to make productive use of technology and the need for the
technology to be transparent to the users. The Strategic Plan cites some of the current work
environment, information technology, and legislative trends that impact the technological directions
of the Agency, such as advancements in image scanning and CD-ROM technology as well as
increased public access requirements. The revised IRM model introduces a range of systems for
integrating data throughout the records management program. The link between the Program
Systems Division and Regional offices is emphasized as an approach for ensuring technological
consistency. This issue also relates to cross-program information  integration.
                                       11              Applicable Guidance Report

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                                                           Summary of Documents
Cross-program  Information  Integration

        The Region X records management evaluation is critical of the decentralized state of
records management functions in the Region whereby several branches have their own paid
records managers and are maintaining and disposing of files according to their own individual
schemes. The report calls for the formal establishment of a centralized records center that is
responsible for the handling of all Federal records and their transfer to a Federal Records Center.
In addition, in Region IV the report recommends that the Region develop a network of records
officers in each program and staff unit to act as a liaison and communication link.

Training

        The evaluation of Superfund records management initiatives discusses personnel training
as a function of the pre-implementation planning for each section. Limitations to training are also
presented as a resource issue, where Headquarters support is needed to help address program
growth.  The Region X evaluation report cites the need for better training in records management
for both clerical and program staff.  The Strategic Plan states the IRM program's commitment to
enhancing productivity through the educated use of technology. To attain this goal, training
programs for IRM professional development, including technical training in records management
are considered to be critical.  Additionally, training for the user community on technological topics,
such as the impact of image processing and the use of new technologies is a priority.
While the majority of the documents reviewed for this project contain legal and administrative
requirements for conducting records management, various studies and other resource materials,
which provided information on the practical application of these requirements, were also reviewed.
These documents either apply subjective analysis to existing programs, or provide element(s) of
the framework necessary to manage EPA's records.
                                        12               Applicable Guidance Report

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                                IV.   APPENDIX
1.            U.S. Environmental Protection Agency, Office of Information Resources
             Management, EPA Information Security Manual. December, 1989

2.            U.S. EPA, Office of the Administrator and Office of Executive Support, Freedom
             of Information Act Manual - 1550. 1986

3.            U.S. Environmental Protection Agency, Office of Solid Waste and Emergency
             Response. Establishing and  Managing a Records Management Program. April 1989

4.            U.S. Environmental Protection Agency, Office of Information Resources
             Management, Information Resources Management Policy Manual (2100).
             November 1987

5.            U.S. Environmental Protection Agency, Office of Information Resources
             Management, National Data Processing Division, IRM Strategic Plan:  1991 - 1995
             (draft). May 1990

6.            U.S. Environmental Protection Agency, Office of Solid Waste and Emergency
             Response, Interim Guidance on Administrative Records for Selection of CERCLA
             Response Actions (#9833.3A). March 1, 1989

7.            U.S. Environmental Protection Agency, Office of Information Resources
             Management, Records Management in the EPA: An Overview for Regional
             Managers (Volume 1): Records Management Fundamentals (Volume 2). January 18
             and 19, 1989

8.            U.S. Environmental Protection Agency, Office of Administration and Resources
             Management, Revised Information Resources Management Model. January 1989

9.            Office of Information Resources Management, Environmental Protection Agency,
             Study to Evaluate Regional Superfund Records Management Initiatives:

             Final Regional Reports. October 20. 1988
             Region VIII  Baseline Summary. May 12, 1988
             Preliminary Assessment Report. November 25. 1987
             Regional Baseline Summaries. November 13, 1987

10.           U.S. Environmental Protection Agency, Office of Emergency and Remedial
             Response and Office of Waste Programs Enforcement, Superfund Document
             Management Study - Initiation Phase Report. December 6, 1989

11.           U.S. Environmental Protection Agency, Office of Solid Waste and Emergency
             Response. System Life Cycle Guidance - 9028. 1989

12.           National Archives and Records Administration, Electronic Records Management:
             Final Rule. May 8, 1990

13.           National Archives and Records Administration, Evaluating a Vital Records
             Program: A NARS Self-Inspection Guide for Federal Agencies. 1983.
                                     13              Applicable Guidance Report

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                                                                      Appendix
14.          National Archives and Records Administration, Office of Records Management,
             Evaluating Files Maintenance and Records Disposition Programs. 1988

15.          National Archives and Records Administration, Federal Archives and Records
             Centers. Chapter 13, "The Federal Vital Records Program," 1979

16.          National Archives and Records Administration, Office of Records Administration,
             Instructional Guide Series: Managing Audiovisual Records. 1990

17.          National Archives and Records Administration, Office of Records Administration,
             Instructional Guide Series: Managing Cartographic And Architectural Records.
             1990

18.          National Archives and Records Administration, Office of Records Administration,
             Instructional Guide Series: Managing Electronic Records. 1990

19.          National Archives and Records Administration, Micrographics: 36 CFR Pan 1230.
             July 2, 1990

20.          National Archives and Records Administration, Records Management Regulations:
             Final Rules. July 2,  1990

21.          National Archives and Records Administration, Vital Records During an
             Emergency. 36 CFR Pan 1236, 1 July 1988.

22.          Federal Records Center - Seattle, Agency Records Management Evaluation.
             Environmental Protection Agency Region 10. June, 1990

23.          Federal Records Center - Atlanta. Records Management Program Field Evaluation.
             Environmental Protection Agency Region 4. April, 1990

24.          U.S. General Services Administration, Information Resources Management
             Services, Electronic  Recordkeeping. July 1989

25.          U.S. General Services Administration, Office of Information Resources
             Management, Forms Management.  1985

26.          U.S. General Services Administration and National Archives and Records Service,
             Office of Federal Records Centers, Records Management Handbook: Disposition of
             Federal Records. 1981

27.          Reagan Administration, Executive Order 12656-Assignment of Emergency
             Preparedness Responsibilities, 18 November  1988
                                       14              Applicable Guidance Report

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TITLE:

U.S. Environmental Protection Agency, Office of Information Resources Management,
EPA Information Security Manual. December 1989
DOCUMENT OVERVIEW:

       The Information Security Manuals are procedural manuals that explain to EPA
managers and staff how to comply with the security responsibilities that were developed
and articulated in the Agency's 1987 Information Security Policy. There are two manuals,
one that deals exclusively with PC security (volume 1) and the other (volume 2) that covers
all types of information assets (paper records, mainframes and minicomputers, information
systems, PCs, and word processors).  Volume 2 is focused on in this review as it is the
most relevant to Regional records management The manual is divided into the following
sections:

             General information
             Information security roles and responsibilities
             Minimal security controls for minicomputer/mainframe installations
             Determining the need for additional controls
             Personnel security and training
             Security for minicomputer and mainframe installations
             Security for personal computers and PC LANs
             Security for word processors
             Security for application system development, operations, and maintenance
             Security for paper records.


APPLICABILITY TO REGIONAL  RECORDS MANAGEMENT:

       This manual covers the procedural aspects of information security. Specifically,
this manual relates to regional records management in the following categories.

Security

       EPA's Information Security Policy (contained in Appendix A of this manual)
establishes a comprehensive, Agency-wide security program to safeguard EPA's
information resources. The policy defines information and applications (or systems) as
either sensitive, such as Confidential Business Information, Privacy Act, or data critical to
performance of primary Agency missions, or as not sensitive and provides definitions of
each.  The three main objectives of the program - information availability, integrity, and
confidentiality - are also discussed along with the information security problem itself.

       Section 3 of this manual discusses minimum security controls that are required for
minicomputer/mainframe installations, PCs, PC LANS, and"word processors. Specifically
the section describes the security measures needed to ensure the basic physical and
environmental protection of ADP equipment and magnetic media. This section also
establishes administrative procedures which govern the use of computers and commercial
software. The measure described in this section can be implemented without first
performing a risk analysis.

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       Section 4 of Volume 2 provides guidance on determining the need for additional
controls beyond those described in Section 3 through the provision of criteria by which the
sensitivity and the degree of sensitivity of each application or collection of information can
be evaluated.

       Section 6 of Volume 2 sets forth security procedures for minicomputer and
mainframe installations,  Section 7 for PCs, and Section 8 for word processors (i.e.,
Lexitrons).  Section 9 deals with security issues and concerns throughout the software life
cycle (from development to operatioirto modification). Security measures for paper and
microform records are discussed in Section 10.  The focus of this section is on significant
quantities of records that constitute manual information systems, rather than normal desk or
office files. This section also provides information on other procedures governing
sensitive information to which paper and microform records must comply (e.g., the Office
of Solid Waste and Emergency Response has issued procedures concerning RCRA
Confidential Business Information). Each of these sections deals with security procedures
through examining threats to the particular system in question and through providing
information on procedures to maintain availability, integrity, and to preserve
confidentiality.

Public  Access

       Public access is discussed implicitly due to the need to monitor security of records.

Staffing

       This manual devotes a chapter to information security roles and responsibilities.
Guidance on information security roles is given through the provision of a framework for
assigning security responsibilities.  The focal point of this framework is the SIRMO.
Chapter 2 then provides guidance on assigning responsibilities to the previously defined
roles. These responsibilities center around three different management control processes
which are described in this manual.

       Section 5 provides guidance on screening and clearance required for persons
involved in the design, development, maintenance, and operation of sensitive automated
systems and facilities. The section also offers guidance on separation of security duties and
the procedures which should be followed.if an employee is terminated or laid off.

Space, Equipment and Materials

       This manual discusses the appropriate environmental conditions for equipment and
magnetic media to ensure that security is maintained.

Organizational  Options

       The Information Security Policy that is provided in Appendix A of this manual
identifies offices within EPA that need to be involved with security issues and lists specific
responsibilities for each office.

Training

       Section 5 states that the Office of Administration and Resources Management is
coordinating the development of information security training programs for the Agency.

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TITLE:

U.S. Environmental Protection Agency, Office of the Administrator and Office of
Executive Support, Freedom of Information Act Manual - 1550. 1986
DOCUMENT OVERVIEW:

       This manual provides guidance on policy and procedures for implementing EPA's"
Freedom of Information Act (FOLA)/Public Information Regulations (Title 40 CFR,
Chapter 1, Pan 2). The Freedom of Information Act is found at 5 U.S.C. 552.

       In general, an office has four options in handling a FOIA request for existing,
located records.  These options may be applied singly or in combination for a given
request. The options are based on the application of nine categories of exemptions. The
options arc: releasing documents; withholding documents that fall under one of the nine
exemption categories; partial withholding of documents that contain both exempt and non-
exempt information and necessary deletions can be made without making the document
unintelligible; and'discretionary release of documents under certain exemption categones if
no important Agency purpose is served by  withholding.

APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:

File Inventory/Structure

       At minimum, in order to assist the public and comply with the law, the manual
identifies a legal requirement for the Regions to be able to locate records requested by the
public.

Public Access

       In complying with FOIA regulations, the Regional offices must provide for the
handling of such requests for public information. This manual documents the policies that
must be followed to determine what may be released, what fees  may be assessed, and what
procedures must be followed to track and file the request.

Records Center Structure and Functions

       The manual further provides guidance on logging, routing and file-keeping of
requests', assessing of fees, appeals, roles and responsibilities of Agency staff, and sample
letters and forms.

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TITLE

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,
Establishing and Managing a Records Management Program. April 1989  •
DOCUMENT OVERVIEW:

       This brochure provides practical information for program managers and staff on
records management, and suggests a framework of issues to be considered to establish a
records management program. The program approach serves to define goals and
objectives, commit resources, and maintain operations. This document identifies the
primary records management activities as:

       •      Organizing records according to uniform classification systems and
             indexing them
             Establishing circulation control procedures
             Converting records to appropriate storage media
             Identifying vital records
             Establishing special procedures for handling sensitive information
             Establishing records retention schedules.

APPLICABILITY TO  REGIONAL RECORDS MANAGEMENT:

       This document provides a framework for approaching the management of records
in the Regional office; it is not a procedural manual.

File  Inventory/Structure

       An inventory checklist is included in the appendix to this brochure. A file
structure/indexing checklist is also included.

Vital  Records

       Defining and making provision for vital records are functions identified in the systems life
cycle development stage. A vital records/disaster recovery plan checklist is included as an
attachment to the document.

Staffing

       The brochure outlines possible records management roles and responsibilities for
various levels of management.

Space, Equipment and Materials

       Resource needs may  be very dependent on the individual Records Systems
developed. A space planning checklist is included,

Life Cycle  Functions

       A summary explanation of the activities conducted in the systems life cycle is given.

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TITLE:

U.S. Environmental Protection Agency, Office of Information Resources Management,
Information Resources Management Policy Manual (21001. November 1987
DOCUMENT OVERVIEW:

      This manual establishes a policy framework for the Information Resources Management
(IRM) program. Information Resources Management means planning, budgeting, organizing,
directing, training and controlling information. If encompasses both information itself and
related resources such as personnel, equipment, funds and technology.

      The manual is intended to provide EPA with a structure for the implementation of the
Brooks Act of 1965, the Paperwork Reduction Act of 1980, the Privacy Act of 1974, the
Freedom of Information Act of 1966, as amended in 1974 and 1986, and policies and regulations
issued by OMB and GSA.'

      The Paperwork Reduction Act of 1980 introduced Information Resources Management to
the Federal Government, emphasizing information as a resource with associated costs and
values. Concepts advanced by the Act through the IRM approach include the life cycle
management of information activities (creation, collection, and use); information functions
(automatic data processing, records management, reports management, and telecommunications);
and the integrated approach to managing information resources (the total systems concept).

APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:

       The policies defined in this manual proscribe- the-frarnewortrunder which the Regions must
manage the information resources under their direction. While the specific  procedures for
implementing these policies are not outlined, as those procedures are developed they must adhere
to these guidelines.

File Inventory/Structure

       This guidance addresses the Agency's responsibilities under the Paperwork Reduction
Act to develop  and maintain an inventory of its information systems and periodically review its
information management activities.

Staffing

       This guidance discusses the need to, under the Paperwork Reduction Act, assign to a
designated senior official the responsibility for the conduct of and accountability  for acquisitions.

Life Cycle Functions

       This manual provides guidance on Agency controls related to basic management functions
of planning, budgeting, acquisition, data management and evaluation of IRM activities; data
standards to provide consistent definition of data and to facilitate cross-media use of data; ADP
resources management; selection, installation, use, maintenance, and administration of voice
communications; security program to safeguard Agency information resources; objectives,
responsibilities, and procedures for collecting information fro the public; objectives,
responsibilities and procedures for records/information management program (further detailed in

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the EPA Records Management Manual); Agency principles for protecting the privacy of
individuals; principles that govern the operation of the EPA library network.

Cross-Program  Information  Integration

       This guidance discusses the need to ensure that EPA's information systems do not
overlap with each other or duplicate the systems of other agencies.

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TITLE:

U.S. Environmental Protection Agency, Office of Information Resources Management,
National Data Processing Division, IRM Strategic Plan:  1991 - 1995 (draff). May 1990
DOCUMENT OVERVIEW:

       The draft Information Resources Management (IRM) Strategic Plan defines the
mission of EPA's IRM Program through 1995 and specifies the accomplishments,
investment areas, resource needs, and responsibilities required to achieve this mission.
This Strategic Plan serves as a component of the Office of Administration and Resources
Management's strategic plan and fulfills the Federal requirement for annually updated
mission-based ERM plans. The Strategic Plan is organized into six sections, including:

       •      Mission statement
              Externalities analysis
              Strengths, weaknesses, opportunities, and threats analysis
              Strategic issues
              Goals and objectives
       •      Strategic directions.

APPLICABILITY TO REGIONAL RECORDS  MANAGEMENT:

       The IRM Strategic Plan provides a framework within which regional records
management over the next five years can be considered. The Plan identifies priorities and
objectives within EPA's IRM Program which can then be applied to regional records
management  Specifically, the Strategic Plan provides direction in the following areas:

Budget Formulation/Constraints

       The IRM Strategic Plan provides priorities and goals within the IRM arena and
identifies some funds (e.g., grant funds) that are available to support attainment of the
long-range IRM goals.

Public  Access

       The public's increasing concerns for and involvement in environmental issues and
the resulting impacts on EPA is one of the main themes in the Strategic Plan. The Strategic
Plan states that the need for sharing information with the public requires reexamining some
of the information services (e.g., records centers, dockets, etc.) that were initially
developed, managed, and funded primarily to serve internal needs as well as considering
public access in the development of any new systems.

Staffing

       The Strategic Plan expresses a need and a commitment to attracting and retaining
highly skilled IRM experts to manage the Agency's increasing investments in advanced
technology. This commitment extends to the need to promote professional development
within the IRM arena.

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Space,  Equipment and Materials

       The Strategic Plan provides information on the review and scrutiny received from
OMB during large and small procurements. The Plan also discusses the development by
OIRM of Agency-wide information architectures for program, administrative, and scientific
systems and hardware/telecommunications, including Information Strategy Plans, priority
acquisitions, and maintenance information.

Life  Cycle Functions

       The Strategic Plan defines the provision of quality service and leadership in the
information area as an IRM goal. Components of this goal include ensuring effective and
appropriate handling of Agency records through:

•      Developing standards and guidelines for records management
•      Reviewing and improving Agency records management practices.

OIRM/NDPD also has an objective of providing appropriate technical assistance and client
support to facilitate efficient use of resources.  This objective will be met through providing
assistance in system design, development, and operation matters.

Technology  Options

       Several components of the IRM Program's mission statement revolve around
technology, especially the need for EPA employees to make productive use of technology
and the need for the technology to be transparent to the users.  The Plan cites some of the
current work environment, information technology, and legislative trends which impact the
technological directions of the Agency, such as advancements in image scanning and CD-
ROM technology as well as increased public access requirements.

       The Strategic Plan discusses some of the potential benefits of technological
additions but stresses the need to weigh any benefits against .the cost of new investments
and potential disruptions. For instance, the Strategic Plan emphasizes the need  in the
records management area to ensure that automated records management solutions are both
cost effective and capable of meeting handling and access requirements.  To provide further
guidance in this area, the IRM Program is assessing the Agency's technology needs and the
capabilities of specific technologies, and then will be procuring the most appropriate
technologies and capabilities to meet Agency-wide needs.  Priority procurements are listed
in the Strategic Plan.

Cross-Program  Information Integration

       One key component of IRM's strategic vision is the need for integrated
environmental information managed as a corporate resource so that it is readily accessible
and in usable form.  The Strategic Plan envisions the development of data integration tools
and activities to complete this vision, including establishing a data administration program,
which provides standards to promote  sharing information, and incorporating integration
tools and activities into EPA Regional offices.  Additionally, the Plan expresses a
commitment to developing policies that facilitate integrated information programs and
developing and managing networks, such as records centers, for effective cross-program
access and sharing.

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 Training

        The Strategic Plan states the IRM Program's commitment to enhancing productivity
 through the educated use of technology.  To attain this goal, training programs for IRM
 professional development, including technical training in records management, are
-considered to be critical. Additionally, training for the user communiry on technological
 topics, such as the impact of image processing and the use of new technologies is a
 priority.
                                         10

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TITLE:

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,
Interim Guidance on Administrative Records for Selection of CERCLA Response Actions
f#9833.3A^. March 1, 1989.
DOCUMENT OVERVIEW:

       This guidance addresses the establishment of Administrative Records under §113 of
CERCLA. The administrative record serves two primary purposes:

       First, the basis for the response selection is set forth in the record, and under §113(j),
judicial review of any issue concerning the adequacy of a response selection is limited to the
record. Second, '§113(k) .requires that the administrative record act as a vehicle for public
participation in the selection of the response action.

       This guidance document discusses the involvement of parties outside the agency,
discusses procedures for compiling and-maintaining the records, and examines the types of
documents that should be included to ensure that the Agency's administrative records meet the
stated purposes.  If the record is incomplete or fails to provide an adequate explanation of the
basis for the Agency's response action selection, the court may remand the case to the Agency for
reconsideration of its decision.

APPLICABILITY TO REGIONAL  RECORDS  MANAGEMENT:

       Since Superfund records comprise a majority of the volume of Regional records, the
compilation of the administrative record, and the records management functions that support that
function, may strongly influence the overall Regional records management procedures.  This
document addresses:

File Inventory/Structure

       The core of this document provides detailed guidelines on the specific  information
that must be included  in, and that which may excluded from, the administrative record.

Security

       Document room security procedures are outlined for maintaining the integrity of the
record files, both in the Regional office and at the site.

Public Access

       Different procedures are outlined for removal and remedial response actions for
publishing a notice of availability, and for making the record available for public inspection
in the vicinity of the site; logging and copying activities for public inspection are detailed.

Staffing

       The guidance identifies key personnel who will be involved and  oversee the compilation
of the administrative record and establishes roles and responsibilities of the Administrative
Record Coordinator, including the coordination responsibilities  with other Regional staff.
                                       11

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Life Cycle Functions

       Recommended location of the record is specified, as is a recommended structure for
indexing the specified documents.

Technology  Options

       The Office of Information Resources Management has granted approval for the
administrative record file to be maintained in microform.
                                       12

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TITLE:

U.S. Environmental Protection Agency, Office of Information Resources Management,
Records Management in the EPA: An Overview for Regional Managers ("Volume IV
Records'Management Fundamentals (Volume 2). January 18 and 19, 1989
DOCUMENT OVERVIEW:

      The Records Management in the EPA volumes are intended to clarify EPA's basic
records management goals and definitions, to explain the records management life cycle,
and to provide instructions for the proper handling of records and for completing the main
records management forms.  The rwo volumes present much of the same information but
were prepared for different audiences - Regional Managers (Volume  1) and those
individuals who deal with records on a day-to-day, more operational  basis (Volume 2).
The volumes are organized into the following sections:

       •      Seminar slides
                    Volume 1  - definitions and an overview of records management
                    goals and the life cycle are provided
                    Volume 2 - definitions and an overview of records management
                    goals are provided as well as objectives and responsibilities for each
                    stage  of the records management life cycle
       •      Policy/official records (both volumes)
       •      Disposition schedule (both volumes)
             Records Management Manual (both volumes)
                    Objectives and responsibilities
                    Reporting requirements
                    Disposition of records
                    Vital  records
                    Filing equipment and  supplies
                    Micrographic management
                    Files maintenance
                    Electronic records
       •      Advanced records management technology (Volume 1)
             Relevant EPA forms and instructions (Volume 2)
           .  Records management references (both volumes).

APPLICABILITY TO  REGIONAL RECORDS  MANAGEMENT:

       These volumes cover many procedural aspects relevant to records management in
the regions, particularly in the Records  Management Manual contained in both volumes, as
well as provide an overview of records management goals and objectives.

Vital Records

       Chapter 4 of the Records Management Manual defines vital records and the purpose
of the Vital Records Program.  This purpose  involves protecting EPA's
records/information that are  necessary for the Agency to continue its key functions and
activities in case of an emergency. This chapter delineates the responsibilities of the key
personnel in the Vital Records Program, including the EPA Emergency Preparedness
Coordinator,  the EPA Records Management Officer, Senior Agency Managers, and Vital
                                      13

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Records Officers. Procedures for transferring vital records to and retrieving these records
from the alternate site are given.

Public Access

       Public access is listed in the overview slides as one of the unique requirements for
EPA records. The need to protect sensitive, proprietary, and other types of information is
also discussed.

Staffing

       The Records Management Manual lists specific responsibilities of staff members in
each of its subsections, i.e., vital records, disposition, electronic records, etc.

Space, Equipment and Materials

       The Records Management Manual prescribes criteria, a checklist, and procedures
for the acquisition of filing equipment and supplies.

Life  Cycle Functions

       The overview section of these volumes defines the records management life cycle
and categorizes each phase as either active or inactive. In Volume 2, specific objectives and
general responsibilities for day-to-day records management in each phase of the life cycle
are given.

       Chapter 7 of the Records Management Manual covers files maintenance. This
chapter provides procedures for file stations, where the Agency's official records are filed,
and for the files custodian who is responsible for the operation of the files station. These
procedures are intended to ensure the integrity of all official records and to keep
information relating to a subject in one location. Specifically, guidance is given on the
preparation and classification of file material and the maintenance of files. A sample Files
Maintenance Plan is also provided.

       Records disposition is covered in detail in the volumes, including reference to 18
U.S. Code 2071, which describes penalties for misuse or management of records, and
definitions of official records, extra reference copies  (non-record material), and personal
papers. The Records Management Manual describes EPA's policy with regard to records
disposition, including its goals of not maintaining inactive records in costly  office space,
releasing filing equipment for reuse, and protecting important records. The  Manual also
lists criteria and procedures for rearing and retrieving records. Additionally, guidelines for
the protection of retired records, especially those subject to the Privacy Act or containing
confidential business information are given.  A copy of the records control schedule (last
revised in 1986) is provided in the volumes.  This schedule details retention and disposition
requirements for program-specific records as well as items common to all offices, including
schedules of daily activities files dealing with the Privacy Act, FOLA, and office
administrative files.

       Chapter 6 of the Records Management Manual discusses micrographic management
for records, excluding the use of Computer Output Microfilm and other ADP hardware.
The chapter provides definitions relevant to micrographics, offers procedures for
maintaining and protecting permanent microform records, and discusses the need to
develop a new records control schedule for disposition of microform records (even if the
                                        14

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paper records are already scheduled). Standards are provided for film tests, inspections (to
ensure that standards are met), and reviews of micrographic systems.

       Chapter 8 offers guidelines on the documentation and preservation of records
created, stored, or transmitted using electronic means, including personal computers, word
processors, or other electronic office equipment- AAtirinoaUy-, electronic records
responsibilities~fbr EPA staff members are given.

       Volume 2 contains copies of relevant EPA, National Archives and Records
Administration, and standard forms as well as instructions for completing each form.
These forms are linked to the relevant stage of the records management life cycle.

Organizational Options

       The Records Management Manual states the objectives of the records management
program and lists the records management responsibilities of various organizations within
EPA.

Technology Options

       The overview slides in the first section of each volume provide general information
on the role of technology in records management, the types of technologies relevant for use
in records management, and some of the characteristics of each technology.

       Chapter 6 then provides extensive information on justifying the need for a
micrographic system, including criteria and format for written feasibility studies, as well as
the review process for proposed acquisitions, and procedures for the purchase/lease of
microfilm equipment or services.

       A section of Volume 1 is devoted to articles on advanced records management
technology, including optical disk, computer-assisted retrieval systems, and image
management systems.
                                       15

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TITLE:

U.S. Environmental Protection Agency, Office of Administration and Resources
Management, Revised Information Resources Management Model. January 1989
DOCUMENT OVERVIEW:

       The Revised Information Resources Management Model was designed to amend the
mission of the Office of Information and Resources Management (OIRM) to include the
records management function. This change in mission is precipitated by the increase in
records management initiatives and the lack of coordination of Regional records
management systems. The revised model is intended to facilitate consistency, use the
Regional IRM Managers network to provide an effective medium for information exchange
and technology transfer, and provide management support and technical direction for the
Regional records management functions.

       The contents of-the revised model are as follows:

       Overall IRM Branch and Section Management
       Central ADP Operations and Support
       Software Development and Management
       Information User Services
       Records Management Support
       Voice, Image, and Data Telecommunication and Networking.

The original model, entitled Regional Office IRM Organizational Model and Resource
Profiles, March 1987, is provided as an attachment.

APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:

Vital  Records

       Life cycle approach is discussed in terms of the high growth rate of the Superfund
program.  Functions to be employed by the records center to ensure the integrity of the files
throughout records control are also identified.

Staffing

       Records management staff functions arc presented in terms of the primary functions
of the records management program and the associated personnel needs for the Regional
program.  The document notes the primary variables to be considered in the allocation of
personnel, including the size of the Region, number of NPL sites, current state of records
management, future plans, and office moves.

Space, Equipment and Materials

       Equipment needs and options for the system are presented in light of the support to
 be provided by GERM under the new model. Information user services are outlined, such
 as the  Regional Office Information Center, and the Regional Office Library.
                                       16

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Records Center Structure and Functions

      The advancements of certain Regions are cited as examples of the implementation of
centralized records centers.

Technology  Options

      A range of systems for integrating data throughout the records management
program are introduced. The link between the Program Systems Division and Regional
offices is emphasized as an approach for ensuring technological consistency.
                                      17

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TITLE:

U.S. Environmental Protection Agency, Office of Information Resources Management,
Environmental Protection Agency, Study to Evaluate Regional Superfund Records
Management Initiatives:

       Final Regional Reports. October 20. 1988
       Region VITI Baseline Summary.  May 12, 1988
       Preliminary Assessment Report. November 25, 1987
       Regional Baseline Summaries. November 13, 1987
DOCUMENT OVERVIEW:

       In an effort to promote coordination of further efforts in managing Superfund
records and to disseminate effective records management techniques, OIRM documented
the success of Regional records management initiatives to improve Superfund
documentation.  The study was conducted in two phases.' In the first phase, conducted in
November 1987, OIRM reviewed Regions I, III, VI, and VII, to provide a baseline for
measuring Regional progress in terms of the management of records required to support the
growing Superfund program requirements. In May 1988, Region VIE was added to the
review as part of the first phase. The second phase, undertaken in August and September
1988, was a series of follow-up reviews to document the further success of the Regional
records management programs since the initial visit

       In phase one. Regions were assessed according to their records management needs,
resources available, current and anticipated resource needs, and the Region's records
management progress to date. For each Region, the discussion is presented according to
the data collection areas employed in the study methodology:

             Project Initiation
             Pre Implementation Planning
             Objectives
             Implementation
             Resources
             Monitoring Efforts and Modification
             Benefits/Costs/Problems
             Outlook.

Exhibits oudining the scope of the Regional initiatives and estimating records growth and
records management resources are included in the document.  Additionally, summary
charts providing a comparison of records management data for all Regions are included as
an attachment.
                             V
       Following the compilation of the baseline summaries, a Preliminary Assessment
was prepared, to present the evaluation of the four Regional initiatives. This report
presents findings and assesses the implications of those findings as they related to each
Region's records management program. As a second pan of the Agency's review of
Regional Superfund records management initiatives, OIRM conducted telephone interviews
of all ten Regions to assess overall program accomplishments and resource needs.

       Based on the telephone survey and findings presented in the preliminary
assessment,, the scope of the baseline.summaries was expanded to document the success of
                                       18

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Region VOTs records management initiative to improve the maintenance of Superfund
documentation. The Region VIE report is presented in the same format as the initial
baseline summaries. •

       As the second phase of the OIRM evaluation. Final Regional Reports were prepared
to document the success over the last six to ten months of four Regional records
management initiatives to improve Superfund records documentation. This report provides
a Region-by -Region overview of progress toward records management objectives for
Superfund records and also assesses the changes in objectives since the initial visit

APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:

Budget  Formulation/Constraints

       The summaries present discussions of budget formulation as it relates to the
implementation and pre-implementation planning for the Superfund records management
program. Funding sources and options used by the Regions are presented.

       Resource constraints as  perceived by the Regions, are presented in the findings for
each Regional review.  Budget constraints are also discussed in the outlook for the
program, as OIRM looked ahead to determine how to meet anticipated needs.

File Inventory/Structure

       File inventory is presented in terms of the features of some of the Regional
programs, such as that  for Regions I and II.

Public Access

       The limitations  for responding to FOIA requests are discussed in terms of staffing
constraints. The amount of staff time spent for Regional responses to requests is also
noted.

Staffing

       Regional perceptions regarding available resources are discussed in terms of the
staffing capabilities for the program. Regional records management staff and functions are
described.

Space,  Equipment and Materials

       Because the space allocations for the Regions vary considerably and because of the
need for space to accommodate the expanding Superfund program records, this topic is
often covered in the discussion of resource constraints, as well as in the implementation
and outlook sections of the reports. Equipment descriptions and innovative methods for
obtaining space in the program planning stages arc presented in the Regional discussions.

Records Center Structure and Functions

       The design and planning of records centers is described in terms of innovative use
of staffing, such as shared staffing  with other programs or Agency areas.
                                      19

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Organizational Options

       The options for implementing the program are provided from several Regional
records management perspectives. Modifications to the initial structure are also provided to
assist in anticipating issues related to program organization and anticipated growth.

Technology Options

       Technology options are presented in terms of storage media, such as
micrographics, being explored in some Regions. Technology is cited particularly as an
area for additional Headquarters support to help Regions deal with anticipated growth in
Superfund records.

Cross-Program  Information Integration

       The primary focus of this analysis was Superfund records, although some
information is applicable to other programs.

Training

       Personnel training is discussed as a function of the pre-implementation planning
section for each section. Limitations to training is also presented as a resource issue, where
Headquarters support is needed to help address program growth.
                                       20

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TITLE:

U.S. Environmental Protection Agency, Office of Emergency and Remedial Response and
Office of Waste Programs Enforcement, Superfund Document Management Study -
Initiation Phase Report. December 6, 1989
DOCUMENT OVERVIEW:

       This report summarizes the findings of a study conducted jointly by OERR and
OWPE to first develop an understanding of the current Superfund document management
environment, in order to quantify the costs and risks associated with current practices and
propose long term solutions for improving the efficiency of document handling; secondly,
to identify cost-effective interim improvements and provide management with
recommendations for improving guidance on document management and records handling
procedures.

       The study was limited to documentation  supporting pre-remedial, remedial, -
removal, and enforcement actions, including financial, technical, enforcement and some
laboratory records. Source data was gathered through individual interviews, working
group meetings, and surveys of site files.

APPLICABILITY  TO REGIONAL RECORDS  MANAGEMENT:

File Inventory/Structure

       The study characterizes the inventory of Superfund records with regard to content,
size, location, and users.

Security/Vital  Records

       The study asserts that there is not a viable security program established for the
Superfund records at the Regional or Headquarters level.  Recommendations arc made for
establishing a process to identify and handle essential documents.

Public Access
                                                                             t

       The study points to a general Region-wide lack of a mechanism and subsequent
lack of follow-through to FOIA requests.

Starring

       The study assembled data on the staffing costs associated with existing filing,
retrieval, copying, and distribution activities. These data are also portrayed in extensive
graphics.

Space, Equipment  and Materials

       Costs associated with floor space, off-site storage, and contractors arc identified
and portrayed in detailed graphics.
                                      21

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Records Center Structure and Functions

      The study describes the problems inherent in most existing central facilities,
including file security and integrity, duplicating and diverse file structures across program
series.

Life Cycle  Functions

      The study summarizes the current procedures in place both at Headquarters and in
the Regions for creation, distribution, storage, and retrieval of Superfund records.
Recommendations are made to develop comprehensive and consistent guidelines for
document handling policies and procedures.

Organizational Options

      The study proposes a preliminary project plan with a high-level concept for the
development of a Superfund Document Management System that would drive the handling
of all Superfund documents.

Technology Options

      A program-wide system solution for managing Superfund documents,
incorporating a multi-media approach including paper, micrographics, and image-based
storage and retrieval technologies is recommended. At a minimum, the study suggests
integration of CERCLIS, RPMS, and WasteLAN data bases
                                       22

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TITLE:

U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response,
System Life Cvcle Guidance - 9028. 1989
DOCUMENT OVERVIEW:

     The guidance is presented in three sections: Overview of the document; a description of the
nine stages of the system life cycle, with specific documentation requirements for each step; and
practice papers that provide examples of various aspects of a life cycle project

     Every information management system that supports the Agency's hazardous waste
program must comply with this directive.  AU projects that follow this directive will also satisfy
the requirements outlined in OIRM's EPA System Design and Development.

APPLICABILITY  TO REGIONAL  RECORDS MANAGEMENT:

     These guidelines are extensive in detail, but are particularly appropriate for any Region that
identifies a need to establish a comprehensive integrated system to handle a series of records. All
records management program elements identified as for this project that address the organizing,
tracking and maintaining of records access arc addressed in this guidance.  This guidance does
not address the broader program issues of organizational options, budget constraints, public
access, or cross program information integration.

Life Cycle Functions

     The guidance is instructive with regard to the administrative requirements involved in the
system life cycle process. Specifically, the guidance informs that the stages of the life cycle may
be altered to better suit a given project as long as the changes are documented in the Project
Management Plan that is developed during the corresponding stage of the life cycle, and are
reviewed and approved to ensure appropriate program management oversight Projects may
move forward  while waiting for approval of the previous stage, with the exception of the
implementation stage. Approval must be obtained before implementation can begin.

     Also, the guidance indicates that each procedure that is followed and decision that is made
within the system life cycle must be documented. Appendix 5 lists the documentation required
by this guidance, the stages in which it is to be created, and the stages in  which it is to be
reviewed and revised. Additional appendices provide copies of suggested outlines for each of the
documents described.
     The focus of the guidance is a detailed discussion of the systems life cycle in terms of the
objectives, decisions, activities and resulting products (documentation) of each of the nine stages:

     •      Initiation - This stage identifies the information management problem and the
            environment within which it exists. A decision is made at the end of this stage
            whether or not to commit resources to exploration of possible solutions to the
            problem. The system is not necessarily assumed to be a new system or an
            automated system.  Alternatives will be discussed in the Concept stage.
                                        23

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     •       Concept - During this stage alternative system concepts arc developed and analyzed,
            and a final system approach is chosen.  This stage provides the framework for the
            remainder of the project. The concept developed here, however, may be refined as
            the project progresses and new requirements are identified.

     •       Definition - During this stage the functional and data requirements identified in the
            Concept stage are defined in greater detail, providing the opportunity for a more
            extensive evaluation and definition of the selected system concept

     •       Design - During this stage the exact specifications of the concept are completed
            based on the functional and data requirements identified  in the Definition stage, and
            a design for the complete system is developed.

            Development - During this stage the concept becomes a  working system as the
            necessary hardware and software arc acquired, and all of the elements are
            integrated. Tne elements of the system, including the data, should be ready for
            implementation at the end of this stage.

            Implementation - During this stage the system is installed at the user location and
            tested to ensure that it is operating according to its specifications. Training of the
            users is provided.

            Production - During this stage the system is fully operational and should be
            operated by the intended users. The system is used to solve the information
            problem originally identified, and modifications are made when necessary.

     •      Evaluation - During this stage the system is reviewed to determine if it operates
            efficiently and effectively addresses the information management problem. This
            stage may be repeated several times during the system's life.

     ^      Archive - This is the final stage of the system's life cycle. It ensures orderly
            termination of the system and the preservation of vital materials that may be needed
            after the system is shut down.

The Appendices to these chapters contain a summary of objectives, decisions, activities, and
products for the particular stages as they are presented in the guidance.

     This guidance includes a chapter titled "Crosscurting Considerations" that discusses, from a
life cycle perspective, topics that have significance in several of the stages of the system life
cycle.
                                       24

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  TITLE:

  National Archives and Records Administration, Electronic Records Management: Final
  Rule, May 8, 1990
  DOCUMENT OVERVIEW:

        This final rule, which became effective onJune 7, 1990, revises NARA regulations
  for Federal agencies' electronic records.  This rule defines electronic records and provides
  procedures for managing electronic records, selecting and maintaining electronic storage
  media, and meeting the legal requirements for the disposition of such records.  The
  Electronic Records Management rule is geared primarily toward the Agency's records
  management staff as well as individual records systems managers.  The rule, which was
  published in the Federal Register, is divided into two main sections - one that deals with the
  program requirements 2nd another that establishes standards for the use, creation,
  preservation, and disposition of electronic records.  An identical rule issued by the General
  Services Administration was published along with the NARA rule.


  APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:

        This NARA rule is extremely applicable to Regional records management,
  especially as the Regions are increasingly considering electronic media as alternatives to
  paper for records systems.  In this rule, the head of each Agency is required to ensure that
  electronic records management is integrated with other records and information resources
  management programs of the Agency. More specific guidelines and standards for
—e4eetronic records system are established in this rule in the following categorie"sT

  Security

        Requirements are given for electronic records security, including restricted  access
  as well as backup and recovery mechanisms.

  Public  Access

        This rule addresses public access in terms of the need to maintain controls over-
  classified, proprietary, and Privacy Act information stored electronically.

  Life Cycle Functions

        In this rule, NARA functional requirements for electronic records are given in the
  following areas.

        •      Procedures for the creation and use of data files in electronic format,
               including technical documentation and disposition instructions.

        •      Requirements for the creation and use of text documents in electronic
               format, including identification, indexing and retrieval methods, security,
               disposition, and standard interchange formats between various agency
               systems.
                                        25

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       •      Procedures for the judicial use of records, such as mandates for
              standardized processes (generation and storage), retrieval approaches,
              security mechanisms, and identification and disposition procedures.

       •      Standards for the retention and the destraction of electronic records.

Technology  Options

       This rule states that Federal agencies should define their requirements, based upon
an agency's individual records management needs, for selecting appropriate electronic
media and systems for storing agency records throughout the life cycle or for converting
from one storage medium to another.

Cross-Program Information Integration

       This rule states that standard interchange formats between various agency systems
should be developed.

Training

       This rule discusses the requirement to train appropriate agency personnel to
safeguard sensitive or classified records. Training also must be provided for users in the
operation, care, and handling of the equipment, software, and media used in a system.
                                        26

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TITLE:

National Archives 'and Records Administration, Evaluating a Vital Records Program:
NARS Self-Inspection Guide for Federal Agencies. 1983
DOCUMENT OVERVIEW:

       The purpose of this self-inspection guide is to assist Federal agencies in evaluating
their vital records programs to ensure compliance with the legal requirements as set forth in
FPMR 101-11.7. This guide is a series of questions which can be answered with a yes or
no. A no response is intended to highlight a potential deficiency in the program which
needs to be addressed. The guide is divided into the following sections:

       •       Planning, establishing, and staffing the program
       •       Evaluating potential hazards
              Identifying vital records
              Selecting protection methods
              Choosing a storage facility
       •  '     Establishing operating procedures
       •       Promoting the program
       •       Reviewing the program.

APPLICABILITY TO REGIONAL  RECORDS  MANAGEMENT:

       These self-inspection guide allows records managers to evaluate their own vital
records programs to determine if they are  meeting the necessary legal requirements.
Specifically, this guide addresses the following areas:

Vital  Records

       Section 2 of the guide is intended to help an agency identify potential threats to vital
records, such as fire, water, etc.  This section also provides questions that consider factors
which should be considered relative to these hazards.

       Section 3's questions are intended to evaluate the identification process of a vital
records program. Section 4 focuses on the selection of protection methods, such as
duplicates, and Section 5 deals with the process of choosing a storage facility.

       Section 6 is concerned with the operating procedures that are established for vital
records programs. These procedures include inventories, indexing, labeling, transfer to
storage, and other issues.  Sample forms and instructions are also provided in this section.

       The questions in Section 7 focus on promoting the vital records program within an
agency. Section 8 provides guidance on factors which should be taken in to.consideration
when conducting a review of the vital records program.

Staffing

       Section 1 of this guide also provides questions on staffing issues associated with a
vital records program.
                                        27

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Organizational Options

       The first section of this guide poses questions on both the planning and the actual
establishment of a vital records program.
                                       28

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 TITLE:

 National Archives and Records Administration, Office of Records Management, Evaluating
 Files Maintenance and Records Disposition Programs. 1988
 DOCUMENT OVERVIEW:

       This guide was developed by the National Archives and Records Administration
 (NARA) to help Federal agencies evaluate their files maintenance and records disposition
 programs. These programs are required by Federal law (44 USC chapters, 29, 31, and 33)
 and the same law requires the National Archives to provide regulations and guidance for
 agencies. The regulations are found in 36 CFR Chapter XII. Guidance is provided
 through.a variety of formal and informal mechanisms, including NARA bulletins, training
 classes, informal assistance, and publications, such as this guide.

       The format of this guide is a series of questions that can be answered with a simple
 "yes" or  "no." A "no" answer to  a question indicates a possible problem that may require
 corrective action to improve an agency's files maintenance and records disposition  •
 program.

 APPLICABILITY  TO REGIONAL RECORDS MANAGEMENT:

       This guide provides Regional records management staff with an excellent source for
 monitoring the compliance of their records management programs with Federal
 requirements. The questions in the guide are easy to follow and can serve as a step-by-step
jjuide to  the proper administration of records management activity.

 File  Inventory/Structure

       Parts n and HI of the guide contain questions that will help records management
 personnel in evaluating their tiles maintenance programs. Following this questionnaire will
 assist in the development and maintenance of an effective filing system that promotes the
 prompt retrieval of needed documents and information.  The questions in parts n and HI
 will also help Regional  records managers save costly storage space through eliminating
 unneeded non-record material using appropriate filing equipment and supplies.

 Staffing

       The guide is designed so  that sections can be extracted, copied and distributed to
 appropriate agency personnel. For example: pans I, II, and IV may be answered by the
 records manager or chief records officer, part II may be answered by each file station (or
 office) supervisor,  and part V may be answered by the records manager or, for large
 agencies, by each records management staff or liaison individual who performs these
 functions.

 Life  Cycle  Functions

       Part I of the guide, "General Program Requirements For Files Maintenance And
 Records Disposition Programs",  is comprised of groups of questions which cover the basic
 elements of files maintenance and disposition programs as required by Federal Law (44
 USC chapters, 29,  31, and 33). Answering these questions with respect to programs in-
                                       29

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place in the Regions will allow records management personnel to assess the compliance of
their management programs with Federal requirements.

       Parts IV and V of the guide assist records management personnel in gauging the
overall effectiveness of their records disposition programs and practices. The questions
seek to ensure the application of general management policies and specific programmatic
elements as required by Federal law.
                                        30

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TITLE:

National Archives and Records Administration, Federal .Archives and Records Centers.
Chapter 13, "The Federal Vital Records Program,"  1979
DOCUMENT OVERVIEW:

       This document is a chapter in a Records Management handbook developed by
NARA. The intent of this chapter is to ensure that Federal agencies are administering a
vital records program so as to protect those records necessary to ensure the continuity of
essential Government activities during and following a national emergency.  This handbook
is aimed at records managers who implement vital records programs in their agencies and is
divided into the following sections:

              Definitions
              Identifying vital records
       •      Providing copies of vital records
              Storing vital records
              Maintaining an effective program.

APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:

       This chapter of NARA's records management handbook outlines requirements for
Federal agencies'  vital records programs.

Vital  Records

       This chapter provides definitions of the two main types of vital records and lists the
three categories that Government department and agencies fall into with regard to vital
records. The chapter also specifics utility and cost as the two key criteria around which a
vital records program should be planned.

       Chapter 13 then turns to the requirements for identifying vital records to ensure that
those records essential to the conduct of emergency functions and those that preserve the
rights and interests of individual citizens and the Government are selected. The chapter
specifies three types of functions which must be considered in this process - mission-
oriented, emergency-oriented, and emergency plan of operations. The chapter then
provides guidance on conducting a survey to identify vital records, including lists of the
types of vital records most common in the Federal government.

       Further guidance is provided on the maintenance of vital records through a
discussion of the four main methods:

       •      Use of existing duplicates at other locations
       •      Creation of duplicates for storage at alternate locations
              Copying existing records
              Transfer of official files.

       Vital records storage is discussed through providing information on key factors
which must be considered, such as choice of location, manner of storage, rotation of
records, and responsibility of custody. Information is also given on the services offered by
Federal Records Centers for vital records storage.  Finally, this chapter stipulates that vital
                                       31

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records programs need to be reviewed at least annually and encourages testing the program
under simulated emergency conditions.

Organizational Options

       The chapter lists several guidelines LU be followed when establishing a vital records
program, including guidance on the appropriate location of certain functions (headquarters
vs. field offices).
                                        32

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TTTUE:

National Archives and Records Administration, Office of Records Administration,
Instructional Guide Series: Managing Audiovisual Records. 1990
DOCUMENT OVERVIEW:

       The National Archives and Records Administration (NARA) Instructional Guide
Series provides Federal agencies with detailed guidance on the management of specific
types of records. Particular emphasis is placed on the proper techniques for identifying and
handling those records that are, or may be appraised to be, permanently valuable and are
therefore intended for transfer to the National Archives. The instructional guides help
agencies create adequate and proper documentation of their activities, differentiate
permanent from temporary records, set up appropriate filing or storage systems, develop
retrieval mechanisms, and monitor the physical conditions under which records are stored

       "Managing Audiovisual Records" part of the NARA Instructional Guide Series,
provides Federal agencies with derailed guidance on the management of audiovisual
records. Audiovisual records are  Federal records in pictorial or aural form that include still
and motion pictures, graphic materials, sound and video recordings, and combination of
media, such as slide-tape productions. This instructional guide is specifically designed to
assist individuals responsible for the creation, maintenance and use, and disposition of
audiovisual records designated for permanent retention in the National Archives. Because
audiovisual records are most likely to be found within the Regional public affairs offices,
recruiting and training  offices, historical offices and libraries, research and development
offices, and grants and projects offices, this manual is most relevant to records
management personnel in these Regional EPA offices and the Regional Records Officer if
one exits.

       The handbook is organized into the following sections:

       •      Introduction
              Locating Audiovisual Records
       •      Scheduling and Disposition
              Potentially Permanent Records
              Record  Elements for Archival Purposes
                     Record Elements
       •      Management of Audiovisual Records: Some Guidelines
                     Filing and Identification
                     Storage and Preservation
              Other NARA Services
                     Courtesy Storage of Permanent Audiovisual Records
                     Stock Film Depository Program
                     National Audiovisual Center
              Disposable Audiovisual Records (Appendix A)
              Series Inventory Form (Appendix B)
       •      Regulations (Appendix C)
              Glossary (Appendix D).

       EPA's Regional offices may refer to this manual for guidance on the administrative
and legal requirements associated with audiovisual records management The requirements
for receiving approval from NARS for the disposition of certain Federal records are
                                       33

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explained in detail in the handbook. Sample forms and schedules are provided that will
assist the reader in taking the necessary steps with regards to the scheduling and disposition
of audiovisual records.

APPLICABILITY TO  REGIONAL RECORDS MANAGEMENT:

       This handbook covers many procedural and program elements relevant to the
management of audiovisual records. In addition, the handbook provides detailed guidance
on the broad technical and legal responsibilities associated with audiovisual records
management.

File Inventory/Structure

       Guidance is provided in the handbook on file inventory and file maintenance of
audiovisual records. Additionally, the handbook lists other services provided by NARA to
facilitate the agency's handling of audiovisual records. These services include courtesy
storage of permanent audiovisual records, a stock file depository program and a National
Audiovisual Center.

Life Cycle  Functions

       The middle sections of this handbook provide guidance on identifying,
inventorying, scheduling and either disposing of or retaining audiovisual records.  These
sections outline general guidance as to the categories of audiovisual'records that are
normally of permanent value, are found in most Federal agencies and that eventually will
become part of the National Archives of the United States. It is stressed in the handbook,
however, that the descriptions are provided for general guidance and must be adopted to
reflect accurately the agency's holdings of audiovisual records. The manual describes the
following categories of audiovisual records as normally having permanent value:

       Still Photography
       Graphic Arts
       Motion Pictures
       Video Recordings
       Sound Recordings

       Permanent records are identified during the scheduling process.  This process is
covered in detail in the handbook, with particular attention paid to the steps involved in
preparing a Standard Form (SF) 115: Request for Records Disposition Authority. The SF
 115, also know as the records schedule, is the official mechanism for analyzing the value
of Government records. An agency's records management office prepares the SF 115 by
describing one or more series of records and by providing instructions for their disposition.
The SF 115 is submitted to the National Archives and Records Administration (NARA) for
review and approval.

       As is the case with other types of records, most audiovisual records are not
permanent. The General Records Schedule 21, Audiovisual Records, provided in
Appendix A of the handbook, list temporary records common to most Federal offices and
 give agencies the authority to dispose of such records without further clearance from
 NARA.  Agencies mus submit an SF 115 to NARA to obtain legal authorization of the
disposition of all other audiovisual records.

       The manual is instructive with regard to specific records management program
 elements. The manual provides guidance to assist in the creation, maintenance and use,


                                        34

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and disposition of audiovisual records.  Key steps in the records management process
addressed in the manual include: filing and identification, inventory, and scheduling and
disposition. The manual also provides guidance on the effective storage and preservation of
audiovisual records. The guidance takes into account  the complex and diverse physical
attributes of audiovisual records that pose some special handling, storage and preservation
problems.
                                       35

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TITLE:

National Archives and Records Administration, Office of Records Administration:
Instructional Guide Series: Managing Cartographic And Architectural Records. 1990
DOCUMENT OVERVIEW:

       The National Archives and Records Administration (NARA) Instructional Guide
Series provides Federal agencies with detailed guidance on the management of specific
types of records. The instructional guides help agencies create adequate and proper
documentation of their activities, differentiate permanent from temporary records, set up
appropriate filing or storage systems, develop retrieval mechanisms, and monitor the
physical conditions under which records are stored.

       This handbook offers guidance in the creation, maintenance and use, and
disposition of maps, aerial photographs,  and architectural and engineering drawings. This
handbook focuses on the steps that agency records managers must take in scheduling the
disposition of maps, aenal photographs, and drawings. The handbook is organized into
the following sections:

       •      Introduction
       •      Scheduling records
       •      Cartographic Records
                     Permanent Cartographic Records
              Aerial Photography
                     Permanent Aerial Photographic Records
              Architectural and Engineering Records
                     Criteria for Selecting Permanent Architectural and Engineering
              Records
                     Criteria for Identifying Significant Buildings or Objects
       •      Recommended Maintenance
       •      Disposable Records (Appendix A)
              Glossary (Appendix B).

       Cartographic and architectural records that are created, received or maintained by
 Federal*agencies, arc Federal records, and must be managed in accordance with
 administrative and legal requirements. "Managing Cartographic and Architectural Records"
 is a helpful guide to the administrative and legal requirements associated with properly
 administering to Agency cartographic and architectural records. The requirements for
 receiving approval from NARS for the disposition of certain Federal records are explained
 in detail in the handbook.

 APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:

       This handbook provides detailed guidance on the broad responsibilities associated
 with cartographic and architectural records management. The handbook covers many
 procedural aspects relevant to cartographic and architectural records management and
 provides copies and interpretations of the relevant regulations and General Records
 Schedules (GRS).
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File Inventory/Structure

       To assist the reader in identifying, filing and inventorying records, the handbook
provides definitions of cartographic records, aerial photographs and architectural and
engineering records. In addition, the document lists, types of each of these records that are
most likely to have enduring historical value and should be scheduled for retention in the
national Archives of the United States.  These descriptions are not meant to be incorporated
verbatim into an agency's schedule, but should serve as guides to the types of records that
have permanent value. The agency is instructed to adapt the descriptions to fit its own
programs.

Vital Records

       Particular emphasis is placed on the proper techniques for identifying and handling
those records that are, or may be appraised to be, permanently valuable and are therefore
intended for transfer to the National Archives.

Life Cycle  Functions

       The manual is instructive with regard to specific records management program
elements.  The manual provides guidance to assist in the creation, maintenance and use,
and disposition of cartographic and architectural records.  Key steps in the records
management process addressed in the manual include:  filing and identification, inventory,
storage and maintenance, and scheduling and disposition. Because maps and drawings
have diverse physical attributes, the handbook also provides some general guidelines for
properly caring for and maintaining these kinds of documents.

       Sample forms and schedules are provided in the handbook that will assist the reader
in taking the necessary steps with regards to scheduling and disposition. The term
"disposition" is used to refer to what is done with records when they are no longer needed
for current business. Disposition possibilities include transferring records from one
Federal agency to  another when functions are transferred, transferring them to federal
records centers, destroying temporary records, and accessing permanent records into the
National Archives of the United States. All these  actions require the prior authorization of
the National Archives and Archives Administration (NARA).  No records may be
destroyed without the approval of the Archivist of the United States.
The preservation and eventual transfer of permanently valuable records to the National
Archives is of special concern  and emphasis. The records may exist on paper or film or as
digital data in geographic information systems (GIS), in land information systems (LIS), or
in computer aided design systems (CAD).

       The handbook outlines the procedures that must be followed by the agency in
obtaining approval from  the Archivist of the United States for the disposition of Federal
records. This process is known as the scheduling process.  In it< an agency records
management official fills out a records schedule (Standard Form 115) in which one or more
records are described and instructions are provided for  their disposition. The SF 115 is
submitted to NARA for review and approval. As a result  of the scheduling process, all
records are categorized as either temporary or permanent.  Temporary records are those
approved by NARA for disposal, either immediately or after a specified retention period.
Permanent records are those determined by NARA to be sufficiently valuable that they
should be preserved by the Federal Government beyond their current administrative, legal,
and fiscal uses.
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       The handbook provides a sample standard Form 115 and a list of all cartographic,
aerial photographic, and architectural and engineering records that are disposable under the
authority of the General Records Schedules (GRS). The National Archives issues the GRS
to provide mandatory disposition instructions for records that are common to several or all
the agencies of the Federal Government. The appropriate GRS for all cartographic, aerial
photographic, and architectural and engineering records is found in Appendix A of this
handbook. The handbook lists as Appendix B a glossary of cartographic and architectural
records management terms. This could prove to be a helpful guide to Agency records
management officials.
                                        38

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TITLE:

National Archives and Records Administration, Office of Records Administration,
Instructional Guide Series: Managing Electronic Records. 1990
DOCUMENT OVERVIEW:

       The handbook "Managing Electronic Records" is addressed to the creators and
users of electronic records, Information Resources Management (IRM) officials, ADP
staff, and agency records managers. The guidance in the handbook applies to all electronic
records systems, whether on micro-, mini-, or mainframe computers, in networked or
stand-alone configurations.  It focuses on electronic records that are parts of automated
information systems. The handbook is organized into the following sections:
    •
             Introduction
             Roles and responsibilities
             Disposition of electronic records: An overview
             Inventorying electronic records  .
             Applying General Records Schedules
             Scheduling records not covered by the General Records Schedules
             Identifying potentially permanent electronic records
             Transfer of permanent electronic records to the National Archives  .
             Maintenance and use of electronic records
             Management Regulations (Appendix A)
             Disposable Electronic Records (Appendix  B).

       EPA's Regional officer may refer to this manual for guidance on the administrative
and legal requirements associated electronic records management. The requirements for
receiving approval from NARA for the disposition of certain Federal records are explained
in detail in the handbook. Sample forms and schedules are provided that will assist the
reader in taking the necessary steps with regards to the scheduling and disposition of
electronic records.Special attention is devoted in the handbook to the application of
NARA's GRS. A GRS describes temporary records that are common among Federal
agencies and authorizes their disposal  without further clearance  from NARA. The current
GRS schedule for electronic records is provided as an appendix in the handbook.

APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:

       This handbook provides detailed guidance on the broad responsibilities associated
with electronic records management. The handbook covers many procedural aspects
relevant to electronic records management  and provides copies and interpretations of the
relevant regulations and General Records Schedules (GRS).

Life  Cycle  Functions

       The crucial role of records disposition in managing electronic records is emphasized
in the handbook. Records disposition  is an integral part of the total records management
program. Records disposition, records creation and records maintenance are equal parts in
the chain of records management activities. A records disposition program represents the
final phase of records management activity and contains these prime objectives:
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       •      The timely and systematic removal of records deemed temporary by the
             creating office, the agency, and the Government for later destruction by the
             agency or a records depository.
       •      The designation of permanent records having sufficient historical and
             archival values to warrant immediate or later transfer to National Archives
             and records Service (NARS) for permanent preservation.

       The manual.is also instructive with regard to specific records management program
elements. Peculiar needs associated with managing electronic records addressed in the
handbook include: records inventory; identifying permanent and temporary records with the
help of the GRS for electronic records; and transferring electronic records of permanent
value to the National Archives. The handbook concludes with a brief review of some
essential maintenance guidelines for electronic records.

Organizational  and Technological  Options

       The manual also provides guidance on organizational and technological options  .
available in managing electronic  records. Technological and organizational considerations
are presented throughout the manual AS the various steps associated with managing and
maintaining electronic records are detailed.
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TITLE:

National Archives and Records Administration, Micrographics: 36 Ch'K Pan 1230. July 2,
1990
DOCUMENT OVERVIEW:

       This rule provides NARA standards for Federal agencies' use of micrographic
technology in the creation, use, storage, retrieval, preservation, and disposition of Federal
records. The Micrographics rule is geared primarily toward agencies' managers and staff
who establish and implement records management programs.  The rule, which was
published on July 2, 1990, in the Federal Register, is divided into three main sections:

       •       General
              Standards for microfilming records
       •       Standards for the storage, use, and disposition of microform records.

APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:

       All records programs which employ micrographics must comply with the standards
established in this rule. This rule applies to a variety of records management functions
including the following:

Space, Equipment and Materials

       The conditions necessary for storing permanent microform records are referenced in
Subpan C.

Life  Cycle  Functions

       Preparation of microform records and identification and indexing requirements are
also discussed in Subpan B. Standards for microform are also given in this section,
including formats for roll film, computer output microfilm, and microfiche. Additionally,
film and image requirements, such as film stock standards,  processing standards, and
quality standards, for permanent, unscheduled, or temporary records,%duplicates, and user
copies records are discussed.

       Subpan C provides standards for storage; specific standards are given for storing
permanent microform records are referenced. This Subpart also discusses inspection
requirements for master films of permanent record microforms and or records microfilmed
to dispose of the original record. Specifics are  given on the type of sample that must be
used, the elements which must be contained in  an inspection, and the reports developed
after an inspection.

       Subpans B and C provide guidance on  microform records disposition.  Subpan B
discusses the procedures necessary to obtain  authorization for the disposition or permanent
or unscheduled microform records. Subpan  C  offers general requirements for disposition
of microform records as well as for originals and permanent records.
                                       41

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TITLE:

National Archives and Records Administration, Records Management Regulations: Final
      July 2,  1990
DOCUMENT OVERVIEW:

       These final rules were published in the Federal Register by the National Archives
and Records Administration (NARA) and are the text of the regulations found in 36 CFR
Parts 1220, 1222, and 1224. In the publication, NARA is revising its regulations to
provide more extensive guidance to Federal agencies about the creation and maintenance of
adequate and proper documentation of Government policies and activities. The revision
updates regulations on the creation of records currently found in Part 1222 of the Chapter •
and records maintenance regulations currently found in pan 1224  under the title of Files
Management. The revision also adds two new definitions to part  1220 and new regulations
regarding the identification of Federal records and the handling of contractor records. The
effective date of the regulations was July 1, 1990.

       Revisions in the rule to Pan 1222 are extensive and focus  on: establishing the
responsibility of NARA to provide guidance to Federal agencies with respect to ensuring
adequate and proper documentation of the policies and transactions of the Federal
Government, including issuing standards to improve the management of records; defining
Federal records; and outlining the responsibilities of each Federal  agency in meeting the
records management requirements of 44 U.S.C. 2904, 3101, and 3102. Also, Subpan C
of Pan 1222 establishes standards for agency recordkeeping requirements.

APPLICABILITY TO  REGIONAL RECORDS MANAGEMENT:

       These rules should be read by all Regional records managers. They  contain
revisions to specific, technical requirements for the creation and maintenance, the  adequate
and proper documentation, and the disposition of Federal records. The rules outline the
responsibilities of each agency in ensuring compliance with applicable Government-wide
policies, procedures, and standards issued by the National Archives and Records
Administration.

Files  Inventory/Structure

       Pan 1220 is revised to update the definition of the term "adequate and proper
documentation". According to this revision, the term is to mean a record of the conduct of
Government business that is complete and accurate to the extent required to document the
organization, functions, policies, decisions, procedures, and essential transactions of the
agency.

Life Cycle Functions

       This publication contains a revised rule entitled, "Disposition of Federal Records"
 which is found in 36 CFR Pans 1220 and  1228. This rule updates, clarifies, and
reorganizes the procedures governing the disposition of Federal records.  It provides
information on what documentary materials are subject to these records disposition
regulations.  This revised rule distinguishes between the scheduling process and the
 resulting schedules. It also establishes procedures for the temporary loan of permanent and
 unscheduled Federal records.
                                        42

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TITLE:

National Archives and Records Administration, Vital Records During an Emergency. 36
CFR Pan 1236, 1 July 1988
DOCUMENT OVERVIEW:

       This NARA final rule, which was published in the Federal Register, provides for
the selection and protection of vital records required in the development of Federal agency
emergency preparedness programs. This rule is aimed at staff who are responsible for
implementing vital records programs.  This rule is divided into the following sections:

       •      Background
             Categories of vital records
             Program considerations
             Vital records storage at Federal Records Centers

APPLICABILITY TO  REGIONAL RECORDS MANAGEMENT:

       This rule provides general information on requirements for vital records programs
and updates requirements that were given previously in the  1951 Bureau of the Budget
Bulletins.

Vital Records

       The rwo primary categories of vital records - emergency operating records and
rights and  interests records - are defined in this rule. The rule then gives guidance on
factors which should be taken into consideration for a vital records program and provides
criteria which should be used to monitor the effectiveness of a vital records program.

       This rule provides information on the vital records storage services offered at
Federal Records Centers.
                                      43

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TITLE:

Federal Records Center - Seattle, Agency Records Management Evaluation. Environmental
Protection Asencv Region 10. June, 1990
DOCUMENT OVERVIEW:

       The Seattle Federal Records Center (FRQ and National Archives Northwest
Region review team conducted an evaluation on the records management practices of EPA
Region 10 on June 5 through June 14. The findings of that evaluation were forwarded to
the National Archives and Records Administration (NARA) in Washington D.C. for
incorporation into the national report on EPA.  This document is comprised of a cover letter
(from FRC to EPA's Region 10) and two sections of the report that was forwarded to
NARA. The two forwarded sections of the report list the significant findings of the
evaluation.

       Tne contents of this report are as follows:

       •      Introduction
       •      Evaluation team
             Offices Visited
             Significant Findings
             Findings by  Office
                    Office of the Regional Administrator
                    Management Division
                    Hazardous Waste Division
                    Environmental Services Division
                    Air and Toxics Division
                    Water Division
       •      List of EPA Permanent Series.

APPLICABILITY  TO REGIONAL RECORDS  MANAGEMENT:

       The report criticizes the headquarters records management program and the lack of
coordination between Headquarters and the Regions. The report cited a need for EPA
headquarters to improve in  the areas of its records management planning, directives,
audiovisual records management and records management inspection. The heart of the
report addresses perceived problems in the Region 10 records management program.
Significant attention is devoted in this report to the records management procedures within
specific offices in Region 10. By reviewing this report. Regional records managers can
apply suggestions regarding Region 10 records management to their own programs.

File  Inventory/Structure

       The report observes that there is little or no standardization of filing systems within
Region 10. According to the report, each office has developed its own filing system, some
more effectively than others. Also, the report notes that there is little standardization of the
contents of case files in many offices.
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Life Cycle  Functions

       The report's criticisms of the Region 10 records management program components
are many and varied.  They include:

       •       The Agency's records schedule is out of date
       •       There  is much duplication of information in the regional office
       •       The provisions of the EPA records schedule are not being applied   .
       •       Permanent records are not being systematically identified, maintained and
              transferred to trie National Archives by Region 10.

Cross-Program Information  Integration

       "The report is critical of the overall structure of the Region 10 records management
program. It focuses its criticism on the decentralized state of records management
functions in Regions  10 whereby several branches have their own paid records managers
and are maintaining and disposing of files according to their own individual schemes.  The
report calls for the formal establishment of a centralized records center that is responsible
for the collection, maintenance, disposition, and transfer to FRC of all Federal records.

Training

       The report cites the need for better training in records management for both clerical
and program staff. Region 10 employees are reportedly only partially familiar with basic
records management concepts such as record versus non-record material, efficient filing
principles, records scries, and records disposition rules.
                                       45

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TITLE:

Federal Records Center - Atlanta, Records Management Program Field Evaluation:
Environmental Protection Agency Region FV. April 1990
DOCUMENT OVERVIEW:

       The Atlanta Federal Records Center (FRC) and National Archives-Southeast
Region review team conducted an evaluation on the records management practices of EPA
Region IV on April 12, 13, 16, 1990.

       The contents of this report are. as follows:

       •      Contacts
             Introduction
             Conclusions
             Recommendations
       •      Agency Evaluation Questionnaire
             Superfund Records
             Implementation of Disposition Schedules
             Training
             Contractors
       •      Permanent records
       •      Scientific and Research and Development Records
       •      Special Records.

       The report emphasizes that the Headquarters records management program simply
must provide more guidance and oversight of regional programs. According to the report,
either no assistance or guidance has been forthcoming, or the regional records management
program has been reticent about carrying them out.  Records schedules, manuals,
handbooks, guidelines, were either out of date or non-existent in Adanta.

APPLICABILITY  TO  REGIONAL RECORDS  MANAGEMENT:

       The report finds that no formal records management program for EPA's Region IV,
until the very recent past, has functioned since the Region was organized in the early
 1970's. The report cites the symptoms that lead to this conclusion and offers
recommendations on  how the Region IV records management program could be improved.
By reviewing this report. Regional records managers can apply suggestions regarding
Region IV records management to their own programs.

File Inventory/Structure

       According to the report, the Region IV records management program could profit
form an inventory of  the records in each of its units, under the direction of the Region IV
Information Services (ISS) chief. At present, nobody in Region IV knows what records
exist or where they are.

Staffing

       The Region's  practice of rotating a records center officer through the program
offices is supported in the report. It is argued that this has been an effective method for
                                       46

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identifying and solving some of the accumulated records problems, and for educating EPA
officials about records management principles and advantages.

Life Cycle  Functions

       The report suggests that EPA Region FV give carerul consideration to its
practice of utilizing contractors for all if its records management program.  The report
stresses that while many activities concerning record keeping are appropriate for contractors
to perform, management should review the policy now in place that develops expertise and
knowledge about EPA records-management situations in contractor personnel but not in
EPA records management officials.

Cross-Program Information Integration

       The report recommends that Region FV develop a network of records officers in
each program and staff unit,  to act as a liaison and communication links. It is suggested
that a formal approach to cross-program integration would be best, with records
management dunes included in a position description at a position and grade high enough to
provide an authority sufficient to carry, out the expected duties.
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TITLE:

U.S. General Services Administration, Information Resources Management Services,
Electronic Recordkeeping. July 1989
DOCUMENT  OVERVIEW:

       The General Services Administration (GSA) Electronic Recordkeeping handbook is
one of a series of GSA handbooks on records and information management which are
intended to help Federal agencies improve their office systems and procedures. The
purpose of this handbook is to promote effective electronic recordkeeping policies and
practices within the Federal government through the provision of guidance, not regulations.
The handbook focuses on methods and procedures which will lead to increased electronic
recordkeeping efficiency, effectiveness, and economy: The intended audience for
Electronic Recordkeeping is primarily managers in the Federal government with records
management responsibilities as well as staff who have operational responsibilities.  This
handbook  is divided into the following chapters:

       •     What is Electronic  Recordkeeping?
       •     Establishing a Management Program
             Creating Electronic Records
             Using Electronic Records
             Security of Electronic Records  •
             Coping with Emergencies
             Disposition of Federal Electronic Records
             Appendix - Sample Electronic Recordkeeping Management Program
             Directive.
 APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:

       This handbook begins with general definitions and background material on
 electronic records and progresses to more specific, procedural issues. Information is
 provided in the following categories:

 File  Inventory/Structure

       Steps that should be followed when inventorying electronic records are provided in
 Chapter 7 of the handbook. Suggestions are given for information which should be
 contained in an electronic records inventory (series or system title, inclusive dates of the
 data, software and hardware used, responsible offices, how records .were created, access
 restrictions, etc.) as well as potential sources of this information.

 Security

       Chapter 5 provides guidance on the security of electronic records based on the
 premise that only properly authorized individuals should have the ability to create, review,
 modify, or delete electronic records. The chapter provides further information on various
 security issues, such as physical protection of equipment, media declassification and
 destruction methods, electromagnetic emanations, and user identification and
 authentication.
                                        48

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Vital Records

       Chapter 6 of the handbook offers guidance in developing contingency plans for
emergency situations with the objectives of preventing or limiting losses, minimizing the
interruption of essential services,'and designating alternatives for continuing essential
services. The handbook discusses optional backup arrangements and potential staff
responsibilities.

Public  Access

       Chapter 4 provides a summary of the major laws which govern public access to
electronic information and their specific requirements. These laws include FOIA, the
Privacy Act, and the Electronic Communications Privacy ACL

Staffing

       Chapter 2 of the handbook provides guidance on establishing a management
program for electronic records. Tne chapter very briefly discusses general responsibilities
for both managers and stall within electronic records.

Space,  Equipment and Materials

       Chapter 2 lists several factors that should be considered prior to purchasing new or
upgrading current electronic recordkeeping systems.  Chapter 5 provides information on
appropriate environmental conditions for equipment and other electronic materials, such as
floppy disks, hard disks, magnetic computer tape, and optical disks.

Life  Cycle  Functions

       Chapter 3 of the handbook discusses methods and techniques for managing records
maintained in electronic media. The chapter presents two approaches to identifying
electronic records - the individual document approach and the record series approach as
well as the advantages and disadvantages of each.  Standards and guidance for
recordkeeping operations, such as filenaming conventions, are also presented.  The chapter
then discusses the implications of various  operating procedures (i.e., saving, copying, and
erasing files) on records management, particularly record integrity.  The importance of
back-ups is also discussed since electronic records generally  are less stable than paper or
microform.

       Chapter 3 defines two types of indexing associated with electronic records - key
field and hierarchies of words or phrases.  Guidance is provided in the implementation of
these indexing schemes.

       Chapters 3 and 4 discuss the credibility and the legal acceptability of electronic
records  and the relationship of these two characteristics to documented procedures and to
periodic reports on the regular practice  of these procedures. This discussion involves
topics such as equipment reliability, integrity of data entered, data processing and methods
used to prevent data loss, software reliability, and time and method for preparing printouts.

       Disposition of electronic records is discussed in Chapter 7.  Specific steps in the
disposition process, such as inventorying,  reviewing existing General Records Schedules,
and developing an agency schedule, are explained, Guidance is also provided on special
handling needed for long-term preservation of electronic records.
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Organizational  Options

       Chapter 2 of the handbook provides guidance on establishing a management
program for electronic records.  The chapter briefly discusses the place of records
management in the organizational hierarchy and the roles and responsibilities of managers
and staff within the records management program.

Technology  Options

       Technology options are discussed with regard to the indexing and retrieval of
electronic records in Chapter 3. Two types of computer software can perform indexing,
retrieving, and modifying procedures - Data Base Management Systems (DBMS) and Full
Text Retrieval Systems. This chapter discusses the advantages and disadvantages of each.
Combinations of the two systems are also presented.

Training

       The handbook stresses the'importance of training individuals who create, edit,
store, retrieve, or dispose of electronic records in understanding basic electronic records
concepts, the technologies, and relevant procedures.  Chapter 1 provides alternatives for
meeting these training needs, including self-learning centers, hotlines, and formal,
recurring classroom training.
                                        50

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TITLE:

U.S. General Services Administration, Office of Information Resources Management,
Forms Management. 1985
DOCUMENT OVERVIEW:

       Forms Management is one of a series of handbooks on records and information
management developed by GS A to assist Federal agencies in improving their office
systems and procedures. This publication focuses on the methods and procedures of forms
management with the objective of providing a strategy for achieving increased forms
efficiency, effectiveness, and economy. Toward this end, information is presented
according to the following sections:

             The Need for Forms Management
             Establishing a Forms Management Program
             Operating the Program
             Estimating Forms Costs
       •      Forms Automation.

Sample forms and organizational activity schedules are included throughout the document
to provide a blueprint for Federal agencies to follow in adapting the GSA strategy to their
needs.

APPLICABILITY TO REGIONAL RECORDS MANAGEMENT:

Budget Formulation/Constraints—

       Resources available to the small versus large agency are considered in the
discussion of staffing and automated system configurations.

File Inventory

       The handbook notes that the forms management staff is responsible for developing
methods and procedures for the storage and distribution of forms in coordination with
forms originating offices and supply facilities. The handbook also describes the role of a
"history file,"  as a historical record for each  form.

Public Access

       The handbook provides  a brief synopsis of the relevance of FOIA to forms
management procedures and namely, that agencies are required to ientify restricted
information including information contained on forms, under the provisions of the ACL

Staffing

       The handbook notes that the forms management staff needs managerial, analytical,
and forms design skills with capabilities in procedural analysis, forms design and
construction standards, associated equipment knowledge, typography and reproduction,
and administrative skills.  The handbook also provides criteria for determining the size of
staff needed to support the program.
                                      51

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Space, Equipment  and Materials

       The handbook discussess the options for automating the forms management
functions and describes the component equipment needed for three example system
configurations, as well as the costs, advantages, and limitations of each configuration.

Organizational Options

       Overall, the handbook notes that IRM responsibilities should be carried out through
an established ERM organization with authority over agency information management
activities. It is noted that the organizational structure of a forms management program will
depend on the size, location, and forms workload of an agency.  The handbook outlines
several components of the organizational structure supporting a forms management system:
personnel, functional relationships, and program functions.

Technology Options

       The handbook notes that existing technology can be used to do many  forms
management- related functions throughout the life cycle of the form. Automation devices
discussed in this section are categoriaed according to the cost of the system and
appropriateness to a small vs. large agency.  The handbook presents three system
configurations illustrative of the type of electronic equipment currently available for use in
automated forms design, composition, and typesetting.

Training

       The handbook provides a brief synopsis of the role of the forms management
program in providing training in the fundamentals of forms management and its interaction
with other agency activities.  It is particularly noted  that the forms management program is
the focal  point for all forms-related activities in an agency.
                                       52

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TITLE:

U.S. General Services Administration and National Archives and Records Service, Office
of Federal Records Centers, Records Management Handbook: Disposition of Federqj
Records. 1981
DOCUMENT OVERVIEW:

       This self-described "records management handbook" provides extensive
background and guidance to all agencies of the Federal government on managing the
disposition of Federal Records.  Records disposition is an integral pan of the total records
management program. Other links in the chain of records management activities, of which
records disposition is an equal pan, include records creation and records maintenance.  A
records disposition program represents the final phase of records management activity.
This handbook discusses the nature of an effective records disposition program. It tells
how to set up the program, how to operate it, and how to measure its effectiveness. It
discusses how a program can be kept current in the face of constantly evolving agency
.programs and records systems and the ever-increasing volume of records created by
Federal agencies. The handbook is organized into the following sections:

              The records disposition program
              The schedule inventory
              The schedule: records values and the appraisal process
              The schedule: applying appraisal standards
              The schedule: assembling, clearing,  issuing
              The schedule: application
              Managing the records disposition program
              Evaluating program effectiveness
              Glossary of terms (Appendix A)
              Statutes affecting records disposition (Appendix B)
              Federal property management regulations affecting records disposition
              (Appendix C).

       It is essential that the Regional EPA offices be aware of the administrative and legal
requirements of Federal agencies in administering to and managing their records disposition
program. The requirements for receiving approval from the National Archives and Records
Service (NARS) for the disposition of certain Federal records are explained in detail in the
handbook. Sample forms and schedules are provided that will assist the reader in taking
the necessary steps with regards to scheduling and disposition.

APPLICABILITY  TO REGIONAL RECORDS MANAGEMENT:

       This handbook provides extensive and detailed guidance on the broad
responsibilities associated with managing a records disposition program. Decisions made
during the disposition process with regard to the status of Federal records bear directly on
the overall effectiveness of an agency's records management program. "Disposition of
Federal Records" is laid out in an accessible and informative format that will be useful for
appropriate Regional personnel to read once thoroughly and refer to thereafter as needed.
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File Inventory/Structure

       Considerable attention is given in the handbook to the procedures involved with
inventorying records. Records inventory is an important step in preparing for the schedule
and disposition of Federal records.

Staffing

       This handbook provides assistance in the staffing necessary for the records
disposition function.

Life Cycle  Functions

       This handbook provides guidance to records management personnel on the
underlying utility of a disposition program. As indicated in the handbook, an effective
program contains these pnme objectives:

              The timely and systematic removal of records deemed temporary by the
              creating office, the asencv, and ihe Government for later destruction bv the
                    ^           cr   .                                        »
              agency or a records depository.
       •      The designation of permanent records having sufficient historical and
              archival values to warrant immediate or later transfer to NARS for
              permanent preservation.

       After briefly explaining the nature of records disposition and its importance to the
total records management undertaking, the handbook provides detailed guidance on the
many components of the records disposition program. Disposition program components
oudined in the manual include:

The Program Directive. Issuance of an agency directive is the first step in establishing a
disposition program.  Such a document, properly worded and distributed to agency
personnel, makes the program official. It signifies that the orderly retirement and
disposition of agency records is a concern. The directive is also the document through
which  the agency  establishes the structure of the program, defines the staffing and
organizational requirements, and outlines the role of NARS in the operation of the program

The Schedule. The schedule is the key to the records disposition program. It  is the
process by which  records arc identified as either temporary or permanent. This process is
comprised of a number of key steps starting with the inventory, of agency records. The
records inventory, the heart  of the schedule, is a list of each type of record or series,
together with an indication of where it is located and other pertinent data. The procedures
to be followed in the inventory process are detailed in  the handbook.  Appraising records is
also part of the schedule process and occurs after the inventory has been completed.
During the appraisal, records and series of records are  placed into "permanent" or
"disposable" categories. Detailed guidance on performing this activity is provided in the
handbook. The final element of the schedule process is the Standard Form 115 (SF 115).
The SF 115, Request for Disposition Authority, is required.for all requests to NARS for
approval of schedules. These forms must be filled out by the agency and reviewed and
approved by NARS before final action may be taken for records. SFs 115 are not required
for records covered by General Records Schedules.  The handbook provides explicit
directions on filling out SFs 115 and taking action pursuant to the outcome of NARS's
review of the forms.
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Training

       Regional records managers can refer to this handbook for assistance in developing
the training necessary for records disposition procedures.
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TITLE:

Reagan Administration, Executive Order 12656 - Assignment of Emergency Preparedness
Responsibilities.  18 November 1988
DOCUMENT OVERVIEW:

       This Executive Order assigns emergency preparedness responsibilities to the
Federal departments and agencies. This order is prepared for managers within departments
and agencies who are responsible for implementing a vital records program, and is divided
into the following main components:

             Pan 1 - Preamble
             Pan 2 - General Provisions
             Pans 3 - 28 - One pan for each depanment or agency.

APPLICABILITY TO REGIONAL  RECORDS MANAGEMENT:

       This order provides information on emergency preparedness responsibilities of
which vital records is an important component for EPA.

Vital  Records

       This Order delineates the general responsibilities of various departments and
agencies for government-wide emergency preparedness.  The order then discusses the
responsibilities of each Federal department and  agency, including factors that need to be
considered in establishing a program, specific requirements for the program, and other
organizations, such as state and local governments, which may need to be coordinated with
in an emergency situation.

       The Executive Order also defines specific responsibilities for each department and
agency. For EPA, both lead responsibilities and support responsibilities are given. An
example of a lead responsibility is the development of plans to prevent or minimize the
ecological impact of hazardous agents.

Staffing

       A brief description of responsibilities and the type of position/expertise necessary to
carry out these responsibilities is given.

Training

       This Executive Order discusses the need for training and education programs that
incorporate emergency preparedness and civil defense information.
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